clayville thermal plant

Clayville Thermal Plant Proposed development of the Clayville Thermal Plant

in the Clayville Industrial Area, Gauteng Province

Environmental Impact Assessment (EIA) Report

GDARD Ref No.: GAUT 002/18-19/E0063

September 2018

Environmental Impact Assessment Report September 2018

Clayville Thermal Plant

Gauteng Province

Prepared by:

Prepared for:

Bellmall Energy (Pty) Ltd

The Piazza, Level 1, The Cape Quarter

72 Waterkant Street

Cape Town

8001

CLAYVILLE THERMAL PLANT, GAUTENG PROVINCE

Final Environmental Impact Assessment Report September 2018

Project Details Page i

PROJECT DETAILS

GDARD Ref No. : GAUT 002/18-19/E0063

Title : Final Environmental Impact Asssessment Report for the Clayville Thermal

Plant in the Clayville Industrial Area, Gauteng Province.

Authors : Savannah Environmental (Pty) Ltd

Thalita Botha

Jo-Anne Thomas

Gabriele Stein

Client : Bellmall Energy Project 325 (Pty) Ltd

Report Status : Final Environmental Impact Assessment Report for the consideration by the

Gauteng Department of Agriculture and Rural Development

Date : September 2018

When used as a reference this report should be cited as: Savannah Environmental (2018) Final

Environmental Impact Assessment Report for the Clayville Thermal Plant in the Clayville Industrial Area,

Gauteng Province.

COPYRIGHT RESERVED

This technical report has been produced for Bellmall Energy Project 325 (Pty) Ltd. The intellectual property

contained in this report remains vested in Savannah Environmental (Pty) Ltd. No part of the report may be

reproduced in any manner without written permission from Savannah Environmental (Pty) Ltd or Bellmall

Energy Project 325 (Pty) Ltd.



Purpose of the EIA Report Page ii

PURPOSE OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Bellmall Energy Project 325 (Pty) Ltd is proposing the installation of a thermal plant utilising a Circulating

Fluidised Bed (CFB) boiler in the Clayville industrial area near Olifantsfontein. The thermal plant, also

referred to as the central plant, is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated

within the Ekurhuleni Metropolitan Municipality. The development footprint of the facility will be

appropriately placed within the project site of approximately 1.76ha in extent. The proposed project is to

be known as the Clayville Thermal Plant.

The purpose of the central plant would be to provide steam to off-takers in the industrial area. It is

proposed to utilise coal fines in combination with syngas and/or natural gas as feedstock for the CFB

boiler. The coal fines will be sourced from mines within the Delmas and Middelburg areas. Syngas will be

sourced from the Bellmall Energy Syngas Plant situated at remote locations. Natural gas will be sourced

from Sasol via an existing gas pipeline situated along Spanner Road (western boundary of the project site)

within the Clayville industrial area. The steam generation plant will have a capacity of up to 240 tons of

steam per hour which is an equivalent of up to 60 MWe. The installation of the Clayville Thermal Plant will

eliminate the need for off-takers to produce their own steam using small boilers located on the off-taker’s

site. The project will also be designed as a Zero Liquid Effluent Discharge (ZLED) facility, and will therefore

provide for the on-site treatment, reuse, and recycling of wastewater.

Bellmall Energy (Pty) Ltd has appointed Savannah Environmental as independent environmental

consultant to undertake the Environmental Impact Assessment (EIA) Process for the proposed Clayville

Thermal Plant. The EIA process is being undertaken in accordance with the requirements of the EIA

Regulations of December 2014 (GNR 326), as amended on 07 April 2017, promulgated in terms of the

National Environmental Management Act (NEMA; Act No. 107 of 1998).

The EIA Phase addresses those identified potential environmental impacts and benefits associated with all

phases of the project including design, construction and operation, and recommends appropriate

mitigation measures for potentially significant environmental impacts. The EIA Report aims to provide the

GDARD with sufficient information to make an informed decision regarding the project.

This final EIA Report consists of the following sections:

» Chapter 1 provides background to the project and the EIA, a summary of the recommendations and

conclusions from the Scoping Report, and the details of the Environmental Assessment Practitioner

(EAP) conducting the EIA.

» Chapter 2 outlines the strategic legal context for the project at a national, regional and local level.

» Chapter 3 provides a description of the project, including feasible alternatives considered, and the

need and desirability of the project.

» Chapter 4 outlines the approach to undertaking the EIA process.

» Chapter 5 describes the existing biophysical and socio-economic environment within and surrounding

the project development footprint.

» Chapter 6 provides an assessment of the potential issues and impacts associated with the Clayville

Thermal Plant and presents recommendations for mitigation of significant impacts.

» Chapter 7 provides an assessment of cumulative impacts associated with the Clayville Thermal Plant

together with other similar developments in the area.

» Chapter 8 presents the conclusions and recommendations based on the findings of the EIA.

» Chapter 9 provides a list of reference material used to compile the EIA Report.



Purpose of the EIA Report Page iii

GDARD REQUIMENT FOR THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT

Savannah Environmental has compiled a table (refer to Table 1 below) which outlines the GDARD

requirements as outlined in the acceptance of the scoping report dated 04 December 2017 and the

comments received from the GDARD on the EIA Report dated 18 July 2018, and where the requirements

have been addressed within this report for ease of reference. The comments received from the GDARD

on the EIA Report as well as the acceptance of the scoping report is included in Appendix B.

Table 1: Information requested by GDARD

No. Information Requirement CROSS REFERENCE IN THIS EIA REPORT

GDARD comments received on the EIA Report

A Alignment of the activity with applicable legislations and

policies

The development has a direct bearing on the National

Environmental Management Act (NEMA) (Act No. 107 of 1998)

(as amended) at both national and provincial levels. The

proposed development corresponds with the activity applied

for under the Environmental Impact Assessment (EIA)

Regulations, 2014, (GN R.983) Listing Notice 1, Activity 25 and

Listing Notice 2 Activity 6 published under the National

Environmental Management Act (NEMA) (Act No. 107 of 1998)

(as amended).

Gauteng Environmental Management Framework, 2015 (GEMF,

2015) identifies the proposed site as Environmental

Management Zone 5, which is the industrial and commercial

development focus zone

It is noted that the listed activities

applied for in section 4.2 correspond

with the project that is proposed and

that the project site is located within

Environmental Management Zone 5.

B Guidelines: GDARD requirements

The Departmental Conservation Plan depicts that there are no

sensitive biodiversity features occur on the proposed site.

However, the applicant compile all specialist study related to

the proposed activity and site for the proposed installation of a

thermal plant, all specialist's studies attached on the report are

noted and considered related to the proposed activity.

Comment noted.

C Alternatives

Project alternatives provided in the Draft Scoping and EIA

Report are supported. The site is not within critical biodiversity

sensitivities therefore the layout plan is supported. The site is

identified as Environmental Management Zone 5 which is the

industrial and commercial development focus zone, therefore

the site is suitable for the proposed activity.

It is recommended that the alternatives must be assessed and

form part of the preferred alternative which consider the use of

sustainable development means which involve the use of solar

geyser, solar energy, rainfall harvesting etc. must form part of

the final Scoping and EIA to be submitted.

The applicant is proposing to utilise

sustainable development means such as

harvesting rainfall, solar water heating

etc. Refer to Chapter 3.



Purpose of the EIA Report Page iv


D Significant rating of impacts

Identification of impacts and the proposed impact assessment

methodology provided in the Draft Scoping and EIA Report is

supported as this will lead to reliable conclusion that the

mitigation measures identified will reduce impacts to an

acceptable level.

It is noted that the impact assessment

methodology used (refer to section 4.4)

is supported by the Department and

that the Department

E Locality map and layout plans or facility illustrations

The locality map must be in colour and overlaid by the

sensitivity map. The Department propose the following

recommendations to be included in the Final Scoping and EIA

Report:

» The layout plan (A3 size) and indicate the site's access

point(s);

» The zoning certificate of the proposed site;

» Comments from Council for Geoscience must be

obtained and submitted as part of the final Scoping and

EIA.

» Comments of the storm water and traffic impact studies

from Ekurhuleni's Department of Road and Storm water.

» A confirmation from the local authority with regards to

provision of bulk services (e.g. water supply, sewerage and

waste disposal, energy, storm water) and related services

such as road infrastructures is required. This must include a

description of the infrastructure, specifications, layout,

capacity and the planned routes must be included in the

final Scoping and EIA.

» Refer to Appendix J for the A3

layout map.

» Refer to Appendix G2 for the

zoning certificate.

» Comments from the Council of

Geoscience were requested on 31 July

2018. Once comments have been

received, these will be submitted to the

Department for consideration.

» Comments from the City of

Ekurhuleni’s Roads and Stormwater

Department were received on 27 July

2018 (refer to Appendix C6.

» In order to obtain confirmation

from the City of Ekurhuleni with regards

to bulk services (e.g. water supply,

sewerage and waste disposal, energy,

stormwater) and related services such as

road infrastructures, a detailed study is

required to be undertaken. It has been

recommended that this study and

confirmation from the City of Ekurhuleni

be obtained prior to the

commencement of the construction

phase.

F Environmental Management Programme (EMPr)

The attached EMPr is noted and appears adequate to address

impacts that may arise because of the proposed development.

Noted.

G Public participation process

The Public Participation Process was conducted to the minimum

requirements of EIA Regulations 2014 and therefore it must be

done and included in the Final Scoping and EIA Report. Under

Appendix C2 Site Notices and Newspaper Advertisements, it is

noted that the Newspaper Advertisements is not attached on

the report as mentioned, therefore the Newspaper

Advertisement must be attached on the final Scoping and EIA.

Evidence the public participation

process undertaken is contained in

Appendix C of the EIAr. The newspaper

tear sheets are contained in Appendix

C2 of the EIAr.

Acceptance of Scoping

1. Please note that the activity for sorting, shredding, crushing,

grinding or bailing of general waste applied for which was listed

in terms of the Government Notice 921, National Environmental

Management: Waste Act (NEM: WA), 2008 (Act No. 59 of 2008),

under Category A, Activity (2),

"The sorting, shredding, grinding, crushing, screening or bailing

Noted, the project no longer triggers an

activity within the National

Environmental Management: Waste Act

(NEM: WA), 2008 (Act No. 59 of 2008.



Purpose of the EIA Report Page v


of general waste at a facility that has an operational area in

excess of 1000m2" has been repealed.

2. The Minister published a Government Notice, (GN) 1093 for the

National Norms and Standards for the sorting, shredding,

grinding, crushing, screening or Bailing of General Waste, 2017

on 11 October 2017. The notice repealed the above-mentioned

waste management activity from Category A and listed it under

Category C, Activity 6, as

"The sorting, shredding, grinding, crushing, screening or bailing

of general waste at a waste facility that has an operational

area that is 1000m2 and more".

The " sorting, shredding, shredding, grinding, crushing ..." activity

no longer requires a waste management licence but requires

the person to register with the Department in accordance with

the Norms and Standards for the sorting, shredding, grinding,

crushing, screening or bailing of general waste, 2017.

The registration must be done within ninety (90) days from the

date of publication of the Norms and Standards in the

Government Gazette (i.e. from 11 October 2017) and prior to

any construction taking place on site.




(NEM: WA), 2008 (Act No. 59 of 2008.

3. In terms of the transitional arrangements of the National Norms

and Standards for the sorting, shredding, grinding, crushing,

screening or bailing of General Waste, 2017 "A person who

submitted an application for a waste management licence for

the repealed waste management activity contemplated in

paragraph 2 of this notice and a decision is still pending on the

date of commencement of this Notice, must consider such an

application withdrawn and such a person must comply with the

National Norms and Standards for the Sorting, Shredding,

Grinding, Crushing, Screening or Bailing of General Waste,

2017."




(NEM: WA), 2008 (Act No. 59 of 2008.

4. It was indicated on the application form that the waste will be

dried and used as feedstock for the boiler. This triggers activity

listed in terms of the Government Notice 921, National

Environmental Management: Waste Act (NEM: WA), 2008 (Act

No. 59 of 2008), under Category A, Activity (6),

"The treatment of general waste using any form of treatment at

a facility that has the capacity to process in excess of 10 tons

but less than 100 tons."

The project no longer triggers an activity

within the National Environmental

Management: Waste Act (NEM: WA),

2008 (Act No. 59 of 2008 as no waste will

be treated.

5. The Department requires Bellmall Energy (Pty) Ltd to amend

the application to remove Activity 2 and include Activity 6.

The project no longer triggers Activity 6

or any other activity within the NEM:WA.

6. The actual "several waste streams" and "other production

facilities" mentioned in page 25 as well as the anticipated

quantities thereof must be stipulated - as the type of air

emissions, quantities and impacts will depend on actual

waste used.

The project no longer triggers an other

activity within the NEM:WA.

7. The municipal waste mentioned under 3.3 in page 25 must

be clearly stipulated as the different types of municipal





Purpose of the EIA Report Page vi


waste may emit different emissions.

8. The Environmental Management Programme cannot be well

determined without specifically stipulating all the wastes and

their individual impacts. The Environmental Management

Programme must consider and include the impacts associated

with the treatment of each type waste



9. The geotechnical assessment must be undertaken by the

suitable qualified specialist.

A Geotechnical Assessment will be

undertaken before the commencement

of construction and the need for such

an assessment has been included in the

EMPr (refer to Appendix H.

10. The layout plan must be A3 size and using different colours on

the layout plan.

The layout plan has been included in

Appendix J.

11. The layout must be scale, clear legible and indicate legend

which corresponds with activity components.

The layout plan included in Appendix J is

legible and includes a legend.

12. Comments from City of Ekurhuleni Department of Environmental

Resource management must form part of the report.

Comments will be requested from the

City of Ekurhuleni Department of

Environmental Resource management

on the EIA Report for public review.

13. It is indicated that an Atmospheric Emissions Licence (AEL) will

be completed only after a decision has been issued by GDARD.

However, an Air Quality Impact Report that considers the

different waste types applied for use in the proposal as well as

their impacts must be submitted for consideration for the review

of the waste licence. The report must consider the specific

waste types applied for and indicate expected emissions from

the development.





Legal Requirements in terms of the EIA Regulations Page vii

LEGAL REQUIREMENTS IN TERMS OF THE EIA REGULATIONS

An overview of the contents of the Scoping Report, as prescribed by Appendix 3 of the 2014 EIA

Regulations (GNR 326); and where the corresponding information can be found within the report is

provided in Table 2.

Table 2: Legal requirements in terms of the EIA regulations

Requirement Location in Report

(a) Details of –

(i) The EAP who prepared the report.

(ii) The expertise of the EAP, including a curriculum vitae.

Chapter 1

Appendix A

(b) The location of the development footprint of the activity on the approved site as

contemplated in the accepted Scoping Report, including –

(i) The 21 digit Surveyor General code of each cadastral land parcel.

(ii) Where available, the physical address and farm name.

(iii) Where the required information in items (i) and (ii) is not available, the

coordinates of the boundary of the property or properties.

Chapter 1

Table 1.1

(c) A plan which locates the proposed activity or activities applied for as well as the

associated structures and infrastructure at an appropriate scale, or, if it is –

(i) A linear activity, a description and coordinates of the corridor in which the

proposed activity or activities is to be undertaken.

(ii) On land where the property has not been defined, the coordinates within which

the activity is to be undertaken.

Chapter 1

(d) A description of the scope of the proposed activity, including –

(i) All listed and specified activities triggered and being applied for.

(ii) A description of the associated structures and infrastructure related to the

development.

Chapter 3

Chapter 4

(e) A description of the policy and legislative context within which the development is

located and an explanation of how the proposed development complies with and

responds to the legislation and policy context.

Chapter 2

(f) A motivation for the need and desirability for the proposed development, including the

need and desirability of the activity in the context of the preferred development footprint

within the approved site as contemplated in the accepted Scoping Report.

Chapter 3

(g) A motivation for the preferred development footprint within the approved site as

contemplated in the accepted Scoping Report. Chapter 3

(h) A full description of the process followed to reach the proposed development footprint

within the approved site as contemplated in the accepted Scoping Report, including –

(i) Details of the development footprint alternatives considered.

(ii) Details of the public participation process undertaken in terms of Regulation 41 of

the Regulations, including copies of the supporting documents and inputs.

(iii) A summary of the issues raised by interested and affected parties, and an

indication of the manner in which the issues were incorporated, or the reasons for

not including them.

(iv) The environmental attributes associated with the development footprint

alternatives focusing on the geographical, physical, biological, social, economic,

heritage and cultural aspects.

(v) The impacts and risks identified including the nature, significance, consequence,

extent, duration and probability of the impacts, including the degree to which

these impacts –

Chapter 3

Chapter 4

Chapter 5

Chapter 6

Chapter 8

Appendix C

Appendix D – F



Legal Requirements in terms of the EIA Regulations Page viii


(aa) Can be reversed.

(bb) May cause irreplaceable loss of resources

(cc) Can be avoided, managed or mitigated.

(vi) The methodology used in determining and ranking the nature, significance,

consequences, extent, duration and probability of potential environmental

impacts and risks.

(vii) Positive and negative impacts that the proposed activity and alternatives will

have on the environment and on the community that may be affected focusing

on the geographical, physical, biological, social, economic, heritage and

cultural aspects.

(viii) The possible mitigation measures that could be applied and level of residual risk.

(ix) If no alternative development footprints for the activity were investigated, the

motivation for not considering such.

(x) A concluding statement indicating the location of the preferred alternative

development footprint within the approved site as contemplated in the

accepted Scoping Report.

(i) A full description of the process undertaken to identify, assess and rank the impacts the

activity and associated structures and infrastructure will impose on the preferred

development footprint on the approved site as contemplated in the accepted Scoping

Report through the life of the activity, including –

(i) A description of all environmental issues and risks that were identified during the

environmental impact assessment process.

(ii) An assessment of the significance of each issue and risk and an indication of the

extent to which the issue and risk could be avoided or addressed by the

adoption of mitigation measures.

Chapter 6

(j) An assessment of each identified potentially significant impact and risk, including –

(i) Cumulative impacts.

(ii) The nature, significance and consequences of the impact and risk.

(iii) The extent and duration of the impact and risk.

(iv) The probability of the impact and risk occurring.

(v) The degree to which the impact and risk can be reversed.

(vi) The degree to which the impact and risk may cause irreplaceable loss of

resources.

(vii) The degree to which the impact and risk can be mitigated.

Chapter 6

Chapter 7

(k) Where applicable, a summary of the findings and recommendations of any specialist

report complying with Appendix 6 to these Regulations and an indication as to how these

findings and recommendations have been included in the final assessment report.

Chapter 6

Chapter 7

Chapter 8

Appendix D – F

Appendix H

(l) An environmental impact statement which contains –

(i) A summary of the key findings of the environmental impact assessment.

(ii) A map at an appropriate scale which superimposes the proposed activity and its

associated structures and infrastructure on the environmental sensitivities of the

preferred development footprint on the approved site as contemplated in the

accepted Scoping Report indicating any areas that should be avoided,

including buffers.

(iii) A summary of the positive and negative impacts and risks of the proposed

activity and identified alternatives.

Chapter 8

(m) Based on the assessment, and where applicable, recommendations from specialist

reports, the recording of proposed impact management outcomes for the development

Chapter 6

Appendix D – F



Legal Requirements in terms of the EIA Regulations Page ix


for inclusion in the EMPr as well as for inclusion as conditions of authorisation.

(n) The final proposed alternatives which respond to the impact management measures,

avoidance, and mitigation measures identified through the assessment.

Chapter 8

(o) Any aspects which were conditional to the findings of the assessment either by the EAP or

specialist which are to be included as conditions of authorisation. Chapter 8

(p) A description of any assumptions, uncertainties and gaps in knowledge which relate to

the assessment and mitigation measures proposed.

Chapter 4

Appendix D – F

(q) A reasoned opinion as to whether the proposed activity should or should not be

authorised, and if the opinion is that it should be authorised, any conditions that should be

made in respect of that authorisation.

Chapter 8

(r) Where the proposed activity does not include operational aspects, the period for which

the environmental authorisation is required and the date on which the activity will be

concluded and the post construction monitoring requirements finalised.

N/A

(s) An undertaking under oath or affirmation by the EAP in relation to –

(i) The correctness of the information provided in the reports.

(ii) The inclusion of comments and inputs from stakeholders and I&APs.

(iii) The inclusion of inputs and recommendations from the specialist reports where

relevant.

(iv) Any information provided by the EAP to interested and affected parties and any

responses by the EAP to comments or inputs made by interested or affected

parties.

Appendix I

(t) Where applicable, details of any financial provision for the rehabilitation, closure, and

ongoing post decommissioning management of negative environmental impacts. N/A

(u) An indication of any deviation from the approved scoping report, including the plan of

study, including –

(i) Any deviation from the methodology used in determining the significance of

potential environmental impacts and risks.

(ii) A motivation for the deviation.

N/A

(v) Any specific information that may be required by the competent authority. N/A

(w) Any other matters required in terms of Section 24(4)(a) and (b) of the Act. N/A

(2) Where a government notice gazetted by the Minister provides for any protocol or

minimum information requirement to be applied to an Environmental Impact Assessment

Report the requirements as indicated in such notice will apply.

N/A



Invitation to comment on the EIA Report Page x

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR SUBMISSION TO GDARD

This final EIA Report has been prepared by Savannah Environmental in order to assess the potential

environmental impacts associated with the proposed activities. This process is being undertaken in support

of an application for Environmental Authorisation from the Gauteng Department of Agriculture and Rural

Development in terms of the National Environmental Management Act (NEMA; Act 107 of 1998).

Members of the public, local communities and stakeholders were invited to comment on the EIA Report for

the Clayville Thermal Plant which was made available for 30-day public review and comment period at

the following locations from 26 June 2018 – 26 July 2018:

» Olifantsfontein Library (c/o Pearce & Mason Avenue, Olifantsfontein, Kempton Park)

» Winnie Mandela Library (Margaret Zyma Street, Tembisa)

» www.savannahSA.com

This final EIA Report includes all comments received as well as responses to those comments. Where

applicable, this final EIA Report has been amended to address these comments. All amendments and/or

additions to this report have been underlined for ease of reference.



Executive Summary Page xi

EXECUTIVE SUMMARY

Background

Bellmall Energy Project 325 (Pty) Ltd is proposing

the installation of a thermal plant utilising a

Circulating Fluidised Bed (CFB) boiler in the

Clayville industrial area near Olifantsfontein. The

thermal plant, also referred to as the central

plant is proposed on Erf 457, Erf 459 and Portion

12 of Erf 508 which is situated within the Ekurhuleni

Metropolitan Municipality. The project site is

approximately 1.76ha in extent. The proposed

project is to be known as the Clayville Thermal

Plant (refer to Figure 1).

The purpose of the central plant would be to

provide steam to off-takers in the industrial area.

It is proposed to utilise coal fines in combination

with syngas and/or natural gas as feedstock for

the CFB boiler. The steam generation plant will

have a capacity of up to 240 tons of steam per

hour which is an equivalent of up to 60 MWe. The

development of the thermal plant in the Clayville

industrial area will provide the opportunity to

utilise an already available resource such as coal

fines which are regarded as a waste by-product

from coal mining, as a fuel to produce steam for

off-takers to utilise in various processes (i.e. direct

heat, process steam, power generation etc.).

The installation of the Clayville Thermal Plant will

eliminate the need for off-takers to produce their

own steam using small boilers located on the off-

taker’s site. The project will also be designed as a

Zero Liquid Effluent Discharge (ZLED) facility, and

will therefore provide for the on-site treatment,

reuse, and recycling of wastewater.

Potential process steam off-takers include:

» Aspen;

» Astral Foods;

» Clover SA;

» Sasko and

» Nestle R&R Ice cream.

The applicant is also considering two additional

off-takers; Norcros Johnson and Vesuvius.

The main infrastructure associated with the

Clayville Thermal Plant includes the following:

» CFB Boiler;

» Steam supply pipes from the central plant to

various off-takers within the Clayville industrial

area;

» Steam condensate return pipes to the central

plant from various off-takers within the

Clayville industrial area;

» Exhaust stack located adjacent to the central

plant;

» Condenser on site for the conversion of steam

back to water;

» Wastewater treatment plant with a capacity

of 6 000kl per day;

» Effluent pipes and clean water supply pipes

connected from the central plant to 5 off-

takers within the Clayville industrial area;

» Holding tanks for the storage of water;

» Storage of diesel within permanent immobile

liquid tanks;

» Silos for the storage of bottom ash, fly ash and

limestone;

» Gas cylinders for the storage of syngas;

» Dome for the storage of coal fines;

» Feedstock holding and processing area;

» Ancillary infrastructure including access

roads, maintenance building, access control

facilities and office.

Potential impacts associated with the

development of the Clayville Thermal Plant are

expected to occur during both the construction

and operation phases. From the conclusions of

the detailed specialist studies undertaken, no

fatal flaws, no-go areas or areas of

environmental sensitivity were identified within

the project site. The potential environmental

impacts associated with the proposed Thermal

Plant include:

» Air Quality and Human Health: The operation

of the Clayville Thermal Plant will generate



Executive Summary Page xii

low emissions which will result in low ambient

SO2, NO2, CO and PM10 concentrations, and

low ambient air quality impacts for the

construction, operation and decommissioning

phase. The proposed development and

associated infrastructure is therefore unlikely

to result in permanent damage to ambient air

quality, and poses a low risk to human health.

Considering the results of the dispersion

modelling and air quality impact assessment,

the operation of the Clayville Thermal Plant is

expected to generate relatively low emissions

from the CFB boiler for the coal fines-only

scenario, and significantly lower emissions for

the Syngas and natural gas scenarios. These

in turn, result in ambient concentrations that

are well below the NAAQS. The risk

associated with the proposed development

from an air quality and human health risk

perspective is therefore considered to be of

low significance and acceptable.

» Heritage Resources: No significant

archaeological, cultural landscape, built

environment or battlefield sites were

recorded on the development site during the

field surveys. No impacts on heritage

resources are expected to occur due to the

development of the Clayville Thermal Plant.

Based on the findings of the Heritage

Assessment the site is considered to be of low

archaeological significance. The impact of

the development of the Clayville Thermal

Plant on the archaeological nature of the site

is considered to be of a low significance with

the implementation of the appropriate

mitigation measures.

» Traffic: Impacts on traffic will be most

significant during the construction phase due

to an increase of heavy vehicles on the

existing road network. However, traffic

volumes associated with the project are not

significant and can be accommodated on

the existing road network with ease.

However, the four-way stop controlled

intersection of Industry Road/ Nut Avenue is

however already over capacity and it is

recommended that the intersection be

signalised in consultation with the relevant

roads authority. Overall the impacts of the

Thermal Plant on traffic will be of a medium to

low significance with the implementation of

mitigation measures. It is concluded that the

development of the Clayville Thermal Plant

will not have a detrimental impact on traffic

or existing roads.

» Cumulative Impacts: Considering the findings

of the specialist assessments undertaken for

the project, cumulative impacts range from a

low to moderate significance and can be

considered as both positive and negative.

Based on a detailed evaluation, the

cumulative impacts associated with the

construction and operation of the Clayville

Thermal Plant and other developments in the

region are considered to be acceptable. The

implementation of the EMPr and

recommended mitigation measures would

assist in mitigating these negative impacts to

an acceptable level as well as enhancing the

positive impacts to a beneficial level.

The findings of the specialist studies undertaken

within this EIA to assess both the benefits and

potential negative impacts anticipated as a

result of the proposed project conclude that

there are no environmental fatal flaws that should

prevent the Clayville Thermal Plant from

proceeding, provided that the recommended

mitigation and management measures are

implemented.



Executive Summary Page xiii

Figure 1: Locality map showing the area proposed for the establishment of the Clayville Thermal Plant within the Clayville industrial area.



Table of Content Page xiv

TABLE OF CONTENTS

PAGE

PROJECT DETAILS ............................................................................................................................................................ i

PURPOSE OF THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT ............................................................................ ii

GDARD REQUIMENT FOR THE ENVIRONMENTAL IMPACT ASSESSMENT REPORT ...................................................... iii

LEGAL REQUIREMENTS IN TERMS OF THE EIA REGULATIONS ..................................................................................... vii

FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT FOR SUBMISSION TO GDARD ............................................ x

EXECUTIVE SUMMARY ................................................................................................................................................... xi

TABLE OF CONTENTS ................................................................................................................................................... xiv

APPENDICES .............................................................................................................................................................. xviii

DEFINITIONS AND TERMINOLOGY ............................................................................................................................. xix

ABBREVIATIONS AND ACRONYMS ........................................................................................................................... xxii

CHAPTER 1 INTRODUCTION ........................................................................................................................................... 1

1.1 Outline of the EIA Report ................................................................................................................................... 2

1.2 Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact

Assessment Report, 2014 (as amended) .................................................................................................................... 2

1.3 Project Overview ................................................................................................................................................ 3

1.4 Requirements for an Environmental Impact Assessment (EIA) ..................................................................... 9

1.5 Conclusions from the Scoping Phase .............................................................................................................. 9

1.5.1 Evaluation of the Proposed Project .............................................................................................................. 9

1.5.2 Risks Associated with the Proposed Project .............................................................................................. 11

1.5.3 Scoping Phase Conclusion and Recommendations................................................................................ 14

1.6 Details and Expertise of the Environmental Assessment Practitioner (EAP) .............................................. 14

CHAPTER 2 POLICY AND LEGISLATIVE CONTEXT ....................................................................................................... 16


Assessment Report, 2014 (as amended) .................................................................................................................. 16

2.2 Regulatory and Legal Context........................................................................................................................ 16

2.3 National Policy and Planning Context ........................................................................................................... 17

2.3.1 National Waste Management Strategy 2011 ............................................................................................17

2.3.2 The White Paper on Integrated Pollution and Waste Management for South Africa, 2000 ............17

2.3.3 National Development Plan (NDP), 2030 ...................................................................................................18

2.3.4 New Growth Path Framework, 2011 ............................................................................................................18

2.3.5 Climate Change Bill, 2018 .............................................................................................................................18

2.3.6 National Climate Change Response Policy, 2011 ....................................................................................19

2.3.7 Industrial Policy Action Plan (IPAP), 2016 / 2017 – 2018 / 2019 ..............................................................20

2.4 Provincial Policy and Planning Context ........................................................................................................ 20

2.4.1. Gauteng Provincial Environmental Management Framework (GPEMF) 2014 ...................................20

2.4.2. Gauteng Integrated Waste Management Policy ....................................................................................22

2.4.3. Review of the 2009 Gauteng Air Quality Management Plan (AQMP)(2018)......................................23

2.5 Local Policy and Planning Context ................................................................................................................ 24

2.5.1. Ekurhuleni Metropolitan Municipality Spatial Development Framework (MSDF), 2015 .....................24

2.5.2 Ekurhuleni Growth and Development Strategy, 2025..............................................................................24

2.5.3 Ekurhuleni Metropolitan Municipality Integrated Development Plan (IDP), 2013/2014 ....................25

2.5.4 Ekurhuleni Metropolitan Municipality Regional Spatial Development Framework (RSDF): Region B,

2015 25

2.6 International Policy .......................................................................................................................................... 26



Table of Content Page xv

CHAPTER 3 PROJECT DESCRIPTION ............................................................................................................................ 28



3.2 Need and Desirability for the Clayville Thermal Plant ................................................................................. 28

3.3 Project Alternatives .......................................................................................................................................... 30

3.3.1 Site Alternatives ...............................................................................................................................................30

3.3.2 Layout Alternatives .........................................................................................................................................32

3.3.3 Technology Alternatives ................................................................................................................................34

3.3.4 Cooling Technology alternatives .................................................................................................................34

3.3.5 The ‘Do-Nothing’ Alternative ........................................................................................................................34

3.4 Description of the Proposed Project............................................................................................................... 34

3.4.1 Infrastructure ....................................................................................................................................................36

3.4.2 Overview CFB Boiler Technology .................................................................................................................38

3.4.3 Recycling of wastewater ...............................................................................................................................40

3.5 Life-cycle Phases of the Thermal Plant .......................................................................................................... 41

3.5.1 Construction Phase .........................................................................................................................................41

3.5.2 Operation Phase .............................................................................................................................................42

3.5.3 Decommissioning Phase ................................................................................................................................43

CHAPTER 4: APPROACH TO UNDERTAKING THE EIA PHASE .................................................................................... 44

4.1. Legal Requirements as per the EIA Regulations for the undertaking of an Environmental Impact


4.2. Relevant legislative permitting requirements ............................................................................................... 45

4.2.1. National Environmental Management Act (No. 107 of 1998) (NEMA)..................................................45

4.2.2. National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA) .......................46

4.2.3. EIA Regulations, 2014 as amended (GNR326) ..........................................................................................47

4.3. Scoping Phase .................................................................................................................................................. 47

4.4. EIA Phase ........................................................................................................................................................... 48

4.4.1. Tasks completed during the EIA Phase .......................................................................................................48

4.4.2. Authority Consultation ....................................................................................................................................49

4.4.3. Public Participation Process ..........................................................................................................................50

4.4.4. Identification and Recording of Issues and Concerns .............................................................................53

4.4.5. Assessment of Issues Identified through the Scoping Process ...............................................................56

4.4.6. Assumptions and Limitations .........................................................................................................................58

4.5. Legislation and Guidelines that have informed the preparation of this Environmental Impact

Assessment Report ...................................................................................................................................................... 58

4.5.1 International Guidelines .................................................................................................................................68

i. The Equator Principles III (June, 2013) ................................................................................................................68

ii. International Finance Corporation (IFC) Performance Standards on Environmental and Social

Sustainability (January 2012) .......................................................................................................................................69

iii. The IFC Environmental Health and Safety (EHS) Guidelines .......................................................................70

CHAPTER 5: DESCRIPTION OF THE RECEIVING ENVIRONMENT ................................................................................. 72



5.2 Regional Setting: Location of the Project Site ............................................................................................... 72

5.3 Climatic Conditions .......................................................................................................................................... 73

5.4 Biophysical Characteristics of the Study Area ............................................................................................. 74

5.4.1 Geology ............................................................................................................................................................74



Table of Content Page xvi

5.4.2 Soils and Agricultural Potential .....................................................................................................................76

5.4.3 Ecological Profile .............................................................................................................................................76

5.5 Access and Transport Routes in the Region .................................................................................................. 78

5.6 Air Quality .......................................................................................................................................................... 78

5.7 Heritage features of the region ....................................................................................................................... 79

5.7.1 Heritage and archaeology ..........................................................................................................................79

5.7.2 Palaeontology (Fossils) ..................................................................................................................................81

5.8 Social and Economic Characteristics of the Project Site and Surrounding Areas ................................... 82

CHAPTER 6: ASSESSMENT OF POTENTIAL IMPACTS .................................................................................................... 83

6.1 Legal Requirements as per the EIA Regulations for the undertaking of a Environmental Impact

Assessment (EIA) Report, 2014 (as amended) ........................................................................................................ 85

6.2. Potential Impacts on Ambient Air Quality ..................................................................................................... 86

6.2.1 Results of Impact Assessment .......................................................................................................................86

6.2.2 Description of Impacts ...................................................................................................................................87

6.2.3 Impact table summarising the significance of impacts on the ambient air quality during

construction and operation (with and without mitigation) ...................................................................................88

6.2.4 Implications for Project Implementation ....................................................................................................90

6.3. Potential Impacts on Heritage Features ........................................................................................................ 90



6.3.3 Impact table summarising the significance of heritage impacts (with and without mitigation) ...91


6.4. Potential Impacts on Traffic ............................................................................................................................. 92



6.4.3 Impact table summarising the significance of traffic impacts (with and without mitigation) ........93


6.5. Impacts related to the Storage and Handling of Dangerous Goods ......................................................... 96

6.5.1 Description of Impacts associated with the Storage and Handling of Dangerous Goods .............97

6.5.2 Impact table summarising the significance of the storage and handling of dangerous goods

(with and without mitigation) .......................................................................................................................................97

6.6. Assessment of the Do Nothing Alternative .................................................................................................... 98

CHAPTER 7: ASSESSMENT OF CUMULATIVE IMPACTS ..............................................................................................100


Assessment Report, 2014 (as amended) ................................................................................................................100

7.2. Approach Taken to Assess Potential Cumulative Impacts .......................................................................101

7.3. Cumulative Impacts Associated with the Development of the Clayville Thermal Plant .......................103

7.3.1. Potential Cumulative Impacts on Air Quality ......................................................................................... 103

7.3.2. Potential Cumulative Impacts on Archaeology and Heritage ........................................................... 104

7.3.3. Potential Cumulative Impacts on Traffic ................................................................................................. 105

7.4. Conclusions Regarding Cumulative Impacts .............................................................................................106

CHAPTER 8 CONCLUSIONS AND RECOMMENDATIONS .........................................................................................108


Assessment Report, 2014 (as amended) ................................................................................................................108

8.2 Assessment Process .......................................................................................................................................109

8.3 Overview of the Clayville Thermal Plant ......................................................................................................110

8.4 Evaluation of the Proposed Project ..............................................................................................................111



Table of Content Page xvii

8.4.1 Impacts on Air Quality and Human Health ............................................................................................. 111

8.4.2 Impacts on Heritage Resources ................................................................................................................ 112

8.4.3 Impacts on Traffic ......................................................................................................................................... 112

8.4.4 Cumulative impacts .................................................................................................................................... 112

8.5 Environmental Costs of the Project versus Benefits of the Project ............................................................116

8.6 Overall Conclusion (Impact Statement) .....................................................................................................116

8.7 Overall Recommendation.............................................................................................................................117

CHAPTER 9: REFERENCES ...........................................................................................................................................119



Appendices Page xviii

APPENDICES

Appendix A: EIA Project Consulting Team CVs

Appendix B: Correspondence with Authorities

Appendix C: Public Participation Information

Appendix C1: I&AP Database

Appendix C2: Site Notices and Newspaper Advertisements

Appendix C3: Background Information Document

Appendix C4: Organs of State Correspondence

Appendix C5: Stakeholder Correspondence

Appendix C6: Comments Received

Appendix C7: Minutes of Meetings

Appendix C8: Comments and Responses Report

Appendix D: Air Quality Impact Assessment

Appendix E: Heritage Impact Assessment

Appendix F: Traffic Assessment

Appendix G: Other Additional Information

Appendix G1: Site Coordinates

Appendix G2: Zoning Certificates

Appendix G3: Site Plan

Appendix H: Environmental Management Programme

Appendix I: EAP Affirmation and Declaration

Appendix J: A3 Maps



Definitions and Terminology Page xix

DEFINITIONS AND TERMINOLOGY

Alternatives: Alternatives are different means of meeting the general purpose and need of a proposed

activity. Alternatives may include location or site alternatives, activity alternatives, process or technology

alternatives, temporal alternatives or the ‘do nothing’ alternative.

Commence: The start of any physical activity, including site preparation and any other activity on site

furtherance of a listed activity or specified activity, but does not include any activity required for the

purposes of an investigation or feasibility study as long as such investigation or feasibility study does not

constitute a listed activity or specified activity.

Commissioning: Commissioning commences once construction is completed.

Construction: Construction means the building, erection or establishment of a facility, structure or

infrastructure that is necessary for the undertaking of a listed or specified activity. Construction begins with

any activity which requires Environmental Authorisation.

Cumulative impacts: Impacts that result from the incremental impact of the proposed activity on a

common resource when added to the impacts of other past, present or reasonably foreseeable future

activities (e.g. discharges of nutrients and heated water to a river that combine to cause algal bloom and

subsequent loss of dissolved oxygen that is greater than the additive impacts of each pollutant).

Cumulative impacts can occur from the collective impacts of individual minor actions over a period and

can include both direct and indirect impacts.

Decommissioning: To take out of active service permanently or dismantle partly or wholly, or closure of a

facility to the extent that it cannot be readily re-commissioned. This usually occurs at the end of the life of

a facility.

Direct impacts: Impacts that are caused directly by the activity and generally occur at the same time and

at the place of the activity (e.g. noise generated by blasting operations on the site of the activity). These

impacts are usually associated with the construction, operation, or maintenance of an activity and are

generally obvious and quantifiable.

Disturbing noise: A noise level that exceeds the ambient sound level measured continuously at the same

measuring point by 7 dB or more.

‘Do nothing’ alternative: The ‘do nothing’ alternative is the option of not undertaking the proposed activity

or any of its alternatives. The ‘do nothing’ alternative also provides the baseline against which the impacts

of other alternatives should be compared.

Endangered species: Taxa in danger of extinction and whose survival is unlikely if the causal factors

continue operating. Included here are taxa whose numbers of individuals have been reduced to a critical

level or whose habitats have been so drastically reduced that they are deemed to be in immediate

danger of extinction.

Emergency: An undesired/ unplanned event that results in a significant environmental impact and requires

the notification of the relevant statutory body, such as a local authority.



Definitions and Terminology Page xx

Endemic: An "endemic" is a species that grows in a particular area (is endemic to that region) and has a

restricted distribution. It is only found in a particular place. Whether something is endemic or not depends

on the geographical boundaries of the area in question and the area can be defined at different scales.

Environment: the surroundings within which humans exist and that are made up of:

i. The land, water and atmosphere of the earth;

ii. Micro-organisms, plant and animal life;

iii. Any part or combination of (i) and (ii) and the interrelationships among and between them;

and

iv. The physical, chemical, aesthetic and cultural properties and conditions of the foregoing that

influence human health and well-being.

Environmental impact: An action or series of actions that have an effect on the environment.

Environmental impact assessment: Environmental Impact Assessment, as defined in the NEMA EIA

Regulations and in relation to an application to which scoping must be applied, means the process of

collecting, organising, analysing, interpreting and communicating information that is relevant to the

consideration of that application.

Environmental management: Ensuring that environmental concerns are included in all stages of

development, so that development is sustainable and does not exceed the carrying capacity of the

environment.

Environmental management programme: An operational plan that organises and co-ordinates mitigation,

rehabilitation and monitoring measures in order to guide the implementation of a proposal and its ongoing

maintenance after implementation.

Heritage: That which is inherited and forms part of the National Estate (Historical places, objects, fossils as

defined by the National Heritage Resources Act of 2000).

Indigenous: All biological organisms that occurred naturally within the study area prior to 1800.

Indirect impacts: Indirect or induced changes that may occur because of the activity (e.g. the reduction

of water in a stream that supply water to a reservoir that supply water to the activity). These types of

impacts include all the potential impacts that do not manifest immediately when the activity is undertaken

or which occur at a different place because of the activity.

Interested and affected party: Individuals or groups concerned with or affected by an activity and its

consequences. These include the authorities, local communities, investors, work force, consumers,

environmental interest groups, and the public.

No-go areas: Areas of environmental sensitivity that should not be impacted on or utilised during the

development of a project as identified in any environmental reports.

Pollution: A change in the environment caused by substances (radio-active or other waves, noise, odours,

dust or heat emitted from any activity, including the storage or treatment or waste or substances.



Definitions and Terminology Page xxi

Pre-construction: The period prior to the commencement of construction, this may include activities which

do not require Environmental Authorisation (e.g. geotechnical surveys).

Rare species: Taxa with small world populations that are not at present Endangered or Vulnerable, but are

at risk as some unexpected threat could easily cause a critical decline. These taxa are usually localised

within restricted geographical areas or habitats or are thinly scattered over a more extensive range. This

category was termed Critically Rare by Hall and Veldhuis (1985) to distinguish it from the more generally

used word "rare.”

Red data species: Species listed in terms of the International Union for Conservation of Nature and Natural

Resources (IUCN) Red List of Threatened Species, and/or in terms of the South African Red Data list. In

terms of the South African Red Data list, species are classified as being extinct, endangered, vulnerable,

rare, indeterminate, insufficiently known or not threatened (see other definitions within this glossary).

Risk: The chance or likelihood of a hazard causing harm to a person, to property or the environment. The

extent of the risk depends not only on the severity of potential harm to the environment but also on other

factors such as the number of people exposed.

Significant impact: An impact that by its magnitude, duration, intensity, or probability of occurrence may

have a notable effect on one or more aspects of the environment.



Abbreviations Page xxii

ABBREVIATIONS AND ACRONYMS

BID Background Information Document

CBOs Community Based Organisations

CDM Clean Development Mechanism

CSIR Council for Scientific and Industrial Research

CO2 Carbon dioxide

D Diameter of the rotor blades

DAFF Department of Forestry and Fishery

DEA National Department of Environmental Affairs

DENC Department of Economic Development and Nature Conservation

DME Department of Minerals and Energy

DOT Department of Transport

DWS Department of Water and Sanitation

EIA Environmental Impact Assessment

EMPr Environmental Management Programme

GIS Geographical Information Systems

GG Government Gazette

GN Government Notice

Ha Hectare

I&AP Interested and Affected Party

IDP Integrated Development Plan

IEP Integrated Energy Planning

km2 Square kilometres

km/hr Kilometres per hour

kV Kilovolt

m2 Square meters

m/s Meters per second

MW Mega Watt

NEMA National Environmental Management Act (Act No 107 of 1998)

NERSA National Energy Regulator of South Africa

NHRA National Heritage Resources Act (Act No 25 of 1999)

NGOs Non-Governmental Organisations

NIRP National Integrated Resource Planning

NWA National Water Act (Act No 36 of 1998)

SAHRA South African Heritage Resources Agency

SANBI South African National Biodiversity Institute

SANRAL South African National Roads Agency Limited

SDF Spatial Development Framework

SKA Square Kilometre Array



Introduction Page 1

CHAPTER 1 INTRODUCTION




within the Ekurhuleni Metropolitan Municipality. The development footprint of the facility will be

appropriately placed within the project site of approximately 1.76ha in extent. The proposed project is to

be known as the Clayville Thermal Plant.

The purpose of the central plant would be to provide steam to off-takers in the industrial area. It is

proposed to utilise coal fines in combination with syngas and/or natural gas as feedstock for the CFB

boiler. The coal fines will be sourced from mines within the Delmas and Middelburg areas. Syngas will be

sourced from the Bellmall Energy Syngas Plant situated at remote locations. Natural gas will be sourced

from Sasol via an existing gas pipeline situated along Spanner Road (western boundary of the project site)

within the Clayville industrial area. The steam generation plant will have a capacity of up to 240 tons of

steam per hour which is an equivalent of up to 60 MWe. The development of the thermal plant in the

Clayville industrial area will provide the opportunity to utilise an already available resource such as coal

fines which are regarded as a waste by-product from coal mining, as a fuel to produce steam for off-

takers to utilise in various processes (i.e. direct heat, process steam, power generation etc.). The

installation of the Clayville Thermal Plant will eliminate the need for off-takers to produce their own steam

using small boilers located on the off-taker’s site. The project will also be designed as a Zero Liquid Effluent

Discharge (ZLED) facility, and will therefore provide for the on-site treatment, reuse, and recycling of

wastewater. The associated skills transfer and demonstration effects of the proposed technology provides

a learning opportunity for future developments of this nature in South Africa.

As the project has the potential to impact on the environment, an Environmental Impact Assessment (EIA)

process is required to be completed in support of an application for Environmental Authorisation prior to

the commencement of construction and operation of the project. The nature and extent of the Clayville

Thermal Plant, as well as the potential environmental impacts associated with the construction, operation

and decommissioning phases are explored in more detail in this EIA Report.

In terms of the EIA Regulations 2014, as amended in April 2017, a Scoping and EIA study is required to be

undertaken for the project. The Scoping Phase of the EIA process identified potential environmental

impacts that may be associated with the proposed Clayville Thermal Plant. The Scoping Report was

accepted by the Gauteng Department of Agriculture and Rural Development (GDARD) in December

2017.

Following this, the applicant consulted with the National Energy Regulator of South Africa (NERSA) in order

to confirm compliance of the proposed project with relevant legislation and to confirm the feedstock type

and source. Confirmation in this regard was received in March 2018. The EIA project schedule was

therefore delayed, and the applicant and specialist consulting team were not in a position to provide the

Competent Authority with all the information requested within the prescribed timeframes. Subsequently,



Introduction Page 2

the applicant requested that the file be closed on 18 May 2018. In terms of Regulation 21(2) of the EIA

Regulations of 2014 (as amended), the findings of the scoping report remain valid and the environmental

context has not changed. Therefore, the EIA process is proceeding from the EIA Phase following the

submission of a new application form.

1.1 Outline of the EIA Report

The EIA Phase addresses those identified potential environmental impacts and benefits associated with all

phases of the project including design, construction and operation, and recommends appropriate

mitigation measures for potentially significant environmental impacts. The EIA Report aims to provide the

GDARD with sufficient information to make an informed decision regarding the project.

This final EIA Report consists of the following sections:

» Chapter 1 provides background to the project and the EIA, a summary of the recommendations and

conclusions from the Scoping Report, and the details of the Environmental Assessment Practitioner

(EAP) conducting the EIA.

» Chapter 2 outlines the strategic legal context for the project at a national, regional and local level.

» Chapter 3 provides a description of the project, including feasible alternatives considered, and the

need and desirability of the project.

» Chapter 4 outlines the approach to undertaking the EIA process.

» Chapter 5 describes the existing biophysical and socio-economic environment within and surrounding

the project development footprint.

» Chapter 6 provides an assessment of the potential issues and impacts associated with the Clayville

Thermal Plant and presents recommendations for mitigation of significant impacts.

» Chapter 7 provides an assessment of cumulative impacts associated with the Clayville Thermal Plant

together with other similar developments in the area.

» Chapter 8 presents the conclusions and recommendations based on the findings of the EIA.

» Chapter 9 provides a list of reference material used to compile the EIA Report.


Assessment Report, 2014 (as amended)

This final EIA Report has been prepared in accordance with the requirements of the EIA Regulations

published on 08 December 2014 (as amended on 07 April 2017), promulgated in terms of Chapter 5 of the

National Environmental Management Act (Act No 107 of 1998). This chapter of the EIA Report includes the

following information required in terms of Appendix 3: Content of Environmental Impact Assessment

Reports:

Requirement Relevant Section

3(a) the details of the EAP who prepared the report and

(ii) the expertise of the EAP, including a curriculum vitae.

The details (including expertise) of the EAP who prepared

the EIA Report as well as the supporting Savannah

Environmental project team are included in Section 1.5.

The CVs of the project team have also been included as

Appendix A.

3(b) the location of the development footprint of the The location of the project site proposed for the



Introduction Page 3


activity on the approved site as contemplated in the

accepted Scoping Report including (i) the 21 digit

Surveyor General code of each cadastral land parcel,

(ii) where available the physical address and farm name

and (iii) where the required information in items (i) and (ii)

is not available, the co-ordinates of the boundary of the

property or properties.

development of the Clayville Thermal Plant is illustrated in

Figures 1.1 and 1.2. Details of the project site are

included in Section 1.2, Table 1.1.

1.3 Project Overview

As a fast emerging economy, South Africa needs to balance the competing need for continued

economic growth with its social needs and the protection of the natural environment. South Africa needs

to grow in its ability to sustain the natural environment through the sustainable management of waste.

According to ESI Africa (2014), coal mining in South Africa has produced approximately a billion tonnes of

discarded thermal-grade coal fines within the past 150 years. Due to the difficult handling and

transportation of coal fines, this waste by-product is discarded into heaps and slurry dams and emits CO2

as it is being stored. Bellmall Energy Project 325 (Pty) Ltd has identified these coal fines as a potential

feedstock for the production of steam to be provided to various industrial off-takers.

Bellmall Energy Project 325 (Pty) Ltd is investigating the installation of a thermal plant utilising a Circulating

Fluidised Bed (CFB) boiler on a site in the Clayville industrial area in Gauteng Province. The thermal plant

will combine high-efficiency combustion of various solid fuels with low emissions, even when burning fuels

with completely different calorific values simultaneously. The feedstock is proposed to be a combination

of syngas/natural gas and coal fines. The purpose of the central plant would be to provide steam to Astral

Foods and other off-takers in the industrial area, thereby eliminating the need for each of these industries

to produce their own steam.

Potential process steam off-takers include (refer to Figure 1.3):

» Aspen;

» Astral Foods;

» Clover SA;

» Sasko; and

» Nestle R&R Ice cream;

The applicant is also considering two additional off-takers; Norcros Johnson and Vesuvius.

The Clayville Thermal Plant and associated infrastructure is proposed to be constructed on Erf 457, Erf 459

and Portion 12 of Erf 508 within the Clayville industrial area (refer to Figure 1.1, Figure 1.2 and Table 1.1).

The thermal plant will generate up to 240 tons of steam per hour which is an equivalent of up to 60 MWe.

The main infrastructure associated with the facility includes the following:

» CFB Boiler;

» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area;

» Steam condensate return pipes to the central plant from various off-takers within the Clayville industrial

area;

» Exhaust stack located adjacent to the central plant;

» Condenser on site for the conversion of steam back to water;



Introduction Page 4

» Wastewater treatment plant with a capacity of 6 000kl per day;

» Effluent pipes and clean water supply pipes connected from the central plant to 5 off-takers within the



» Storage of diesel within permanent immobile liquid tanks;

» Silos for the storage of bottom ash, fly ash and limestone;




» Ancillary infrastructure including access roads, maintenance building, access control facilities and

office.

Steam generated at the central plant will also be utilised to generate power via steam turbines. In

accordance with the requirements of NERSA, individual turbines for each industrial off-taker being supplied

with steam from the central plant will be located within the central site. These turbines will be owned by

the various steam off-takers, and each turbine will be sized to each off-taker’s requirements. Should the

electricity output of an individual turbine exceed 10MW, an environmental authorisation will be required to

be obtained. Separate applications for authorisation will be undertaken once the details of these turbines

are fully defined.

Potential steam off-takers include:

» Coca-Cola Beverages SA;

» Actom-Wilec;

» Adcock Ingram;

» Aspen;

» Astral Foods;

» Clover SA;

» Nampac;


» RSC Steel;

» Spar;

» Tiger Brands;

» Sasko; and

» Hulamin.

Table 1.1: A detailed description of the project site identified for the development of the Clayville

Thermal Plant

Province Gauteng

Municipality Ekurhuleni Metropolitan Municipality

Ward number(s) 1

Nearest residential areas Clayville East (~1.1km east), Tswelapele (~1.8km west) and Clayville (~1.95km

north west)

Farm name(s) and number(s) Erf 457,

Erf 459, and

Portion 12 of Erf 508

SG 21 Digit Code (s) » T0JR00360000045700000



Introduction Page 5

» T0JR00360000045900000

» T0JR00360000050800012

Current zoning Industrial Use – The affected properties are located within the Clayville

Industrial Area and are zoned as Industrial 1.

Current land use Erf 459 is being used for industrial purposes, while Erf 457 and Erf 12 of 50 are

currently vacant land.

Site Co-ordinates Northern-most extent: 25°58’8.65’’ S 28°14’5.71’’ E

Eastern-most extent: 25°58’10.33’’ S 28°14’7.01’’ E

Southern-most extent: 25°58’15.93’’ S 28°13’59.47’’ E

Western-most extent: 25°58’14.26’’ S 28°13’58.17’’ E

Centre point: 25°58’12.35’’ S 28°14’ 2.40’’ E

More details regarding the proposed project are included within Chapter 3 of this Report.



Introduction Page 6

Figure 1.1: Locality map showing the area proposed for the establishment of the Clayville Thermal Plant within the Clayville Industrial Area



Introduction Page 7

Figure 1.2: Locality map showing the affected properties which form the project site proposed for the development



Introduction Page 8

Figure 1.3: Locality map showing the affected properties in relation to the potential process steam off-taker sites.



Introduction Page 9

1.4 Requirements for an Environmental Impact Assessment (EIA)

In accordance with Section 24(5) of the National Environmental Management Act (No. 107 of 1998)

(NEMA), and the 2014 Environmental Impact Assessment (EIA) Regulations (GNR 326) the development of

the Clayville Thermal Plant and associated infrastructure requires Environmental Authorisation (EA) from the

Competent Authority (CA), the Gauteng Department of Agriculture and Rural Development (GDARD).

Environmental Authorisation (EA) required for the project is subject to the completion of a full Scoping and

Environmental Impact Assessment (S&EIA) process as the proposed project entails, amongst others, the

development of facilities or infrastructure for any process or activity which requires a permit or licence or

an amended permit or licence in terms of the national or provincial legislation governing the generation or

release of emissions, pollution or effluent (Activity 6, Listing Notice 2 (GNR 325)).

This EIA process is therefore being conducted in support of an application for EA (previous GDARD

Reference Number: GAUT 002/17-18/I0004), and is also intended to support an Atmospheric Emissions

License (AEL) required in terms of Section 21 of the National Environmental Management: Air Quality Act

(No. 39 of 2004) (NEM:AQA) and the List of Activities resulting in Atmospheric Emissions (GNR 893) from the

Atmospheric Emissions Licensing Authority (AELA), the Ekurhuleni Metropolitan Municipality. The process of

applying for an AEL will be completed following the completion of the EIA process, once EA has been

granted for the project.

An EIA is an effective planning and decision-making tool for the project developer as it allows for the

identification and management of potential environmental impacts. It provides the opportunity for the

developer to be fore-warned of potential environmental issues, and allows for the resolution of issues

reported on in the Scoping and EIA Reports, as well as a dialogue with interested and affected parties

(I&APs).

1.5 Conclusions from the Scoping Phase

1.5.1 Evaluation of the Proposed Project

From the Scoping Study undertaken, it was concluded that the potential positive and negative impacts

identified to be associated with the construction and operation of the Clayville Thermal Plant are

anticipated to be at a site-specific or localised level, with few impacts extending to a local or national

extent. The following section provides a summary of the findings of the specialist studies undertaken.

» Air Quality: The construction of the Clayville Thermal Plant has the potential to impact on the ambient

air quality of the area by increasing concentrations of the various gases and particulates, especially

during the operation phase of the plant. The impact is expected to be of a low significance. The

significance of the impact will be confirmed through a detailed assessment undertaken during the EIA

phase. Climate change impacts associated with the development of the thermal plant relates to the

emission of greenhouse gases that will contribute to the global phenomenon of anthropogenic climate

change. Climate change is projected to effect many environmental changes across the globe. The

contribution of the Clayville Thermal Plant to global warming is expected to be very low due to



Introduction Page 10

relatively low emissions of GHGs and the global effect will not be directly measurable. The downwind

sector from the thermal plant is predominantly east-southeast to west-southwest of the facility, i.e.

downwind under the prevailing west-northwest to east-northeast. There are two residential areas in

close proximity to the project site and includes Clayville East (1.1km north east) and Tswelopele (1.8km

to the west). A risk exists that emissions from the Clayville Thermal Plant may result in ambient

concentrations of the air pollutants in the nearby residential areas that exceeds the health based

NAAQS. The project site is located in an industrial area which provides a buffer between the thermal

plant and the residential areas. It was recommended that air dispersion modelling utilising the DEA

recommended SCREEN3 model to predict ambient concentrations of air pollutants resulting from the

Thermal Plant for emissions during the operational phase be undertaken. It was furthermore

recommended that a comprehensive air quality impact assessment report in the format prescribed by

the Department of Environmental Affairs (DEA) in support of the Atmospheric Emission License (AEL)

application be compiled for the Thermal Plant.

» Ecology: No impacts on ecology are expected to occur due to the highly transformed and disturbed

nature of the affected properties as well as the highly fractured and isolated nature of the area. There

are no form of noteworthy natural biodiversity, ecological functions and services as well as biotic

interactions within the project site. Most of the vegetative species comprises of weeds, pioneers and

Invasive Alien Plants (IAPs). Bare patches, devoid of vegetation, are also present within Erf 457 and

Portion 12 of Erf 508 and has resulted in soil compaction and some sheet erosion. Due to the

ecological conditions as well as the industrial setting of the project site, it was concluded that no

further ecological investigation is required to be undertaken.

» Archaeological and Heritage Resources: The construction phase of the Clayville Thermal Plant may

impact on archaeological resources due to the construction activities which include excavation.

Stone Age sites are expected to occur within the project site and could be impacted by the

development. The impacts of the construction activities on the archaeological and heritage resources

include potential damage to and destruction of archaeological and heritage sites, indirect impacts

including impact on the cultural landscape and residual risks including the depletion of the

archaeological record of the broader region. The impact is expected to be of a low-medium

significance and will be confirmed through a detailed assessment and fieldwork during the EIA phase.

» Palaeontological Resources: Loss of palaeontological heritage could occur during the construction

phase of the Clayville Thermal Plant. Construction activities could result in the damage and

destruction of the resources or sealing in of fossils below the ground surface making these no longer

available for scientific consideration. Even though the project site is located within very high

palaeontological sensitivity zone, the project site is highly disturbed from previous and current industrial

buildings, infrastructure and roads, and any surface fossils that may occur in the Vryheid Formation

would be very weathered and unrecognisable. Therefore the impact will be of a low significance.

Due to a lack of fossil heritage located within the project site, it was concluded that no further study

was required for the EIA phase.

» Socio-economic aspects: The construction of the Clayville Thermal Plant will result in both positive and

negative impacts. During the construction phase the positive impacts will include temporary

employment opportunities, skills development and household income leading to improved standard of

living. These impacts are expected to be of medium significance. Negative impacts expected during

the construction phase include a change in the demographics of the area due to an influx of




jobseekers, increased pressure on basic services and social and economic infrastructure, an increased

demand in housing within the broader area and an increase in traffic and impacts on movement

patterns. These impacts are expected to be of low and medium significance. Positive and negative

impacts are expected to occur with the operation of the Clayville Thermal Plant. Positive impacts

include employment opportunities, skills development, household income that will improve the

standard of living. These impacts are expected to be of low-medium significance. The negative

impact expected during operation is the deterioration of quality of public health due to combined

emissions from the operating thermal plant. The expected significance of the negative impact is

medium. Another impact that will possibly occur during operation is traffic impacts which are

expected to be of low significance. From the above identified potential impacts it is concluded that

the positive impacts outweigh the negative impacts from a social perspective. Only potential impacts

associated with increased traffic are required to be further investigated through a detailed assessment

within the EIA Phase.

» Impacts Related to the Storage and Handling of Dangerous Goods: During the operation phase, the

Thermal Plant will require the storage of materials which may be considered to be dangerous goods,

including chemicals for the wastewater treatment plant and diesel. The facilities or infrastructure for

storage and handling of a dangerous good will be located in containers with a combined capacity of

80m³ (cubic metres). These substances will be stored on-site in appropriate storage vessels within

bunded areas/ on impervious surfaces. The storage and handling of dangerous goods has the

potential to result in soil and/or water contamination should any spillages/leakages occur. The impact

is expected to be of medium significance. Appropriate mitigation measures will be included within the

Environmental Management Programme such that the risk of the impact occurring is minimised and

appropriately managed.

» Cumulative Impacts: The project site is located within the centre of the Clayville industrial area that is

zoned for industrial use, within Zone 5 of the Gauteng Province EMF and within an area where further

industry is planned. Other industrial facilities within the area include Nestle Ice Cream, Coca-Cola

Beverages, Sasko and Astral Foods. Positive cumulative impact associated with the thermal plant

include the reduction of waste by utilising waste as a feedstock. From a cumulative perspective, it is

anticipated that the development of the Clayville Thermal Plant will not result in unacceptable risk or

loss to the environment. This is supported by the fact that the site is located within the Clayville

industrial area and with Zone 5 according to the GPEMF and can therefore be considered as a site

which would have been developed for some type of industry. It is also considered unlikely that the site

will be used for agricultural purposes due to its location within the industrial area, the limited land

capability of the project site and also due to the current land zoning of the site.

No environmental fatal flaws or impacts of very high significance were identified to be associated with the

development of the Clayville Thermal Plant on the identified project site during the Scoping Phase. This

conclusion will be confirmed through a detailed investigation of the development footprint by the

independent specialist studies within the EIA Report.

1.5.2 Risks Associated with the Proposed Project

Figure 1.4 provides the environmental sensitivity map compiled on the basis of the findings of the Scoping

Study. No environmental sensitivities were identified within the project site. The most significant risk




associated with the project is the potential for increase in air quality impacts associated with the operation

phase of the project. Detailed investigation of impacts of the Clayville Thermal Plant on air quality will be

required to be undertaken in order to confirm the significance of potential impacts and risks. During the

Olifantsfontein Business Forum on 03 August 2017, concerns regarding traffic impacts during the

construction and operation of the thermal plant were raised. A Traffic Impact Assessment will be

undertaken to assess the significance of traffic impacts.




Figure 1.4: Scoping Phase Environmental sensitivity map illustrating the sensitive environmental features located within the Clayville Thermal

Plant project site




1.5.3 Scoping Phase Conclusion and Recommendations

The findings of the Scoping Study were based primarily on a desktop assessment, and based on this

assessment no environmental fatal flaws associated with the Clayville Thermal Plant and associated

infrastructure within the project site were identified. Therefore, no reason was identified for the project not

to be evaluated further in a detailed EIA study.

The facility layout will be assessed in detail and the potential impacts of the development, as identified

during the Scoping Phase, will be ground-truthed by the independent specialist studies that form part of

the EIA Study (as per the Plan of Study for the EIA included in the final Scoping Report). The independent

specialist studies will also provide recommendations for the implementation of avoidance strategies

(where possible) and mitigation and management measures (if required) to ensure that the final

recommended facility layout retains an acceptable environmental impact and considers all highly

sensitive features located within the project site.

1.6 Details and Expertise of the Environmental Assessment Practitioner (EAP)

Savannah Environmental has been appointed by Bellmall Energy Project 325 (Pty) Ltd as independent

consultants to undertake the required EIA Process. Savannah Environmental is a leading provider of

integrated environmental and social consulting, advisory and management services with considerable

experience in the fields of environmental assessment and management. The company is wholly woman-

owned (51% black woman-owned), and is rated as a Level 2 Broad-based Black Economic Empowerment

(B-BBEE) Contributor as the company is an Exempted Micro Enterprise (EME). The company was

established in 2006 with a clear objective to provide services to the infrastructure development sector. The

undertaking of studies involving all environmental-related disciplines has allowed for considerable

experience to be gained in the fields of environmental impact assessment and management. Savannah

Environmental’s team have been actively involved in undertaking environmental stud ies over the past 12

years, for a wide variety of infrastructure development projects throughout South Africa.

The EIA process for the Clayville Thermal Plant is being managed by Jo-Anne Thomas. She is supported by

Thalita Botha and Gabriele Stein.

» Jo-Anne Thomas is a Director at Savannah Environmental (Pty) Ltd. Jo-Anne has a Master of Science

Degree in Botany (M.Sc. Botany) from the University of the Witwatersrand, and is registered as a

Professional Natural Scientist (400024/2000) with the South African Council for Natural Scientific

Professions (SACNASP). She has gained extensive knowledge and experience on potential

environmental impacts associated with electricity generation and transmission projects through her

involvement in related EIA processes over the past 20 years. She has successfully managed and

undertaken EIA processes for infrastructure development projects throughout South Africa.

» Thalita Botha is the principle author of this report. She holds a Bachelor degree with Honours in

Environmental Management and has two (2) and a half years of experience in the environmental field.

Her key focus is on environmental impact assessments, public participation, environmental




management plans and programmes, as well as mapping using ArcGIS for a variety of environmental

projects.

» Gabriele Stein is a Social and Public Participation Consultant at Savannah Environmental. Gabriele has

a Bachelor of Arts Honours Degree in Anthropology (B.A. Honours) from the University of Johannesburg

(UJ). She has 10 years of experience as a Social Consultant in the field of public participation and

social research. Her experience includes the professional execution of public participation consulting

for a variety of projects, and includes the management and coordination of public participation

processes for EIAs for projects in a wide range of sectors, including the infrastructure sector. Gabriele is

responsible for managing the Public Participation process required as part of the EIA for this project.

Curricula Vitae (CVs) detailing Savannah Environmental teams expertise and relevant experience are

provided in Appendix A.

In order to adequately identify and assess potential environmental impacts as well as evaluate

alternatives, Savannah Environmental has appointed several specialist consultants to conduct specialist

studies, as required. Details of these specialist studies are included in Chapter 4. The curricula vitae for the

EIA specialist consultants are also included in Appendix A.



Policy and Legislative Context Page 16

CHAPTER 2 POLICY AND LEGISLATIVE CONTEXT

This Chapter provides an overview of the policy and legislative context within which the Clayville Thermal

Plant and associated infrastructure is proposed. It identifies environmental legislation, policies, plans,

guidelines, spatial tools, municipal development planning frameworks and instruments that are applicable

to this activity and are to be considered in the assessment process which may be applicable or have

relevance to the proposed project.



This chapter of this finalEIA report includes the following information required in terms of Appendix 3:

Content of Environmental Impact Assessment reports:


3(e) a description of the policy and legislative context

within which the development is located and an

explanation of how the proposed development complies

with and responds to the legislation and policy context.

The policy and legislative context at a national,

provincial and local level associated with the

development of the Clayville Thermal Plant has been

considered throughout this chapter. A description of

how the project responds to the identified policy and

legislative context is also included.

2.2 Regulatory and Legal Context

The regulatory hierarchy for the development of the Clayville Thermal Plant consists of three tiers of

authorities who exercise control through both statutory and non-statutory instruments - that is National,

Provincial and Local levels.

At National Level, the main regulatory agencies are:

» NERSA

» South African National Roads Agency (SANRAL): This Agency is responsible for the regulation and

maintenance of all national routes.

At the Provincial Level, the main regulatory agencies are:

» Gauteng Department of Agriculture and Rural Development – This department is the competent

authority identified for the project. This department aims to conserve the environment and its

resources, promote sustainable use, protect and continually enhance environmental assets, enhance

socio-economic benefits and employment creation for present and future generations from a healthy

environment.

» Provincial Heritage Resources Authority Gauteng (PHRAG) - This department identifies, conserves and

manages heritage resources throughout the Gauteng Province.

At the Local Level, the local and municipal authorities are the principal regulatory authorities responsible

for planning, land use and the environment. In the Gauteng Province, the local, district and metropolitan




municipalities play a role. For the Clayville Thermal Plant, the local level authority is the Ekurhuleni

Metropolitan Municipality. The Ekurhuleni Metropolitan Municipality is responsible for the issuing of

Atmospheric Emissions Licenses (AELs) under the National Environmental Management: Air Quality Act (No.

39 of 2004) (NEM:AQA) for activities within its area of jurisdiction.

2.3 National Policy and Planning Context

The following national policies are considered to be relevant to the development of the Clayville Thermal

Plant.

2.3.1 National Waste Management Strategy 2011

Waste management has become a challenge within South Africa due to rapid growth, urbanisation and

consumerist population. The National Waste Management Strategy 2011 recognises the limited ability of

landfills to absorb solid and liquid waste. “Through the country’s commitment to sustainable development,

South Africa aims to balance the broader economic and social challenges of a developing and unequal

society while protecting environmental resources”. This can be achieved though the implementation of

various processes such as re-using, recycling and recovery of waste.

The National Waste Management Strategy lists eight main strategic goals which include:

» Promote waste minimisation, re-use, recycling and recovery of waste.

» Ensure the effective and efficient delivery of waste services.

» Grow the contribution of the waste sector to the green economy.

» Ensure that people are aware of the impact of waste on their health, well-being and the environment.

» Achieve integrated waste management planning.

» Ensure sound budgeting and financial management for waste services.

» Provide measures to remediate contaminated land.

» Establish effective compliance with and enforcement of the National Waste Act.

The Strategy follows the same management hierarchy approach as the National Waste Act. This hierarchy

identifies the avoidance and reduction of waste as the foundation of the approach.

2.3.2 The White Paper on Integrated Pollution and Waste Management for South Africa, 2000

The White Paper places emphasis on preventative strategies which aims to minimise waste and prevent

pollution. The White Paper recognises the crucial role which the private sector and civil society plays along

with the government to ensure sustainable and effective pollution and waste management in South

Africa. One of the fundamental approaches of this policy is to prevent pollution, minimise waste, and to

control and remediate impacts. According to the White Paper, management of waste will be

implemented in a holistic and integrated manner, and will extend over the entire waste cycle, from

“cradle to grave”, including the generation, storage, collection, transportation, treatment, and final

disposal of waste.

Through the implementation of the White Paper, the government aims to:

» Encourage the prevention and minimisation of waste generation and thus pollution at source;

» Encourage the management and minimisation of the impact of unavoidable waste from its generation

to its final disposal;




» Ensure the integrity and sustained “fitness for use” of all environmental media , i.e. air, water and land;

» Ensure that any pollution of the environment is remediated by holding the responsible parties

accountable;

» Ensure environmental justice by integrating environmental considerations with the social, political and

development needs and rights of all sectors, communities and individuals; and

» Prosecute non-compliance with authorisations and legislation.

2.3.3 National Development Plan (NDP), 2030

The National Development Plan (NDP) 2030 is a plan prepared by the National Planning Commission in

consultation with the South African public which is aimed at eliminating poverty and reducing inequality

by 2030. The NDP aims to achieve this by drawing on the energies of its people, growing and inclusive

economy, building capabilities, enhancing the capacity of the state and promoting leaderships and

partnerships throughout society. While the achievement of the objectives of the NDP requires progress on

a broad front, three priorities stand out, namely:

» Raising employment through faster economic growth

» Improving the quality of education, skills development and innovation

» Building the capability of the state to play a developmental, transformative role.

The Clayville Thermal Plant is in-line with the National Development Plan as the development will create

employment opportunities which could assist in addressing poverty issues.

2.3.4 New Growth Path Framework, 2011

The purpose of the New Growth Path (NGP) Framework is to provide effective strategies towards

accelerated job-creation through the development of an equitable economy and sustained growth. The

target of the NGP is to create 5 million jobs by 2020. With economic growth and employment creation as

the key indicators identified in the NGP, the framework seeks to identify key structural changes in the

economy that can improve performance in terms of labour absorption and the composition and rate of

growth. To achieve this, government will seek to, amongst other things, identify key areas for large-scale

employment creation, as a result of changes in conditions in South Africa and globally, and to develop a

policy package to facilitate employment creation in these areas.

The construction and operation of the Clayville Thermal Plant will aid in the creation of sustainable

employment and is therefore is considered to be in line with the NGPF.

2.3.5 Climate Change Bill, 2018

On 8 June 2018 the Minister of Environmental Affairs published the Climate Change Bill (“the Bill”) for public

comment. The Bill provides a framework for climate change regulation in South Africa aimed at governing

South Africa’s sustainable transition to a climate resilient, low carbon economy and society. The Bill

provides a procedural outline that will be developed through the creation of frameworks and plans. The

following objectives are set within the Bill:

a) provide for the coordinated and integrated response to climate change and its impacts by all

spheres of government in accordance with the principles of cooperative governance;




b) provide for the effective management of inevitable climate change impacts through enhancing

adaptive capacity, strengthening resilience and reducing vulnerability to climate change, with a

view to building social, economic, and environmental resilience and an adequate national

adaptation response in the context of the global climate change response;

c) make a fair contribution to the global effort to stabilise greenhouse gas concentrations in the

atmosphere at a level that avoids dangerous anthropogenic interference with the climate system

within a timeframe and in a manner that enables economic, employment, social and

environmental development to proceed in a sustainable manner.

Off-takers in the Clayville industrial area utilise small boilers located on-site to produce steam. The

installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site. It is

expected that the removal of individual boilers will reduce emissions within the industrial area. The CFB

boiler will utilise coal fines (i.e. a waste by-product from coal mining) as a fuel source. These coal fines are

commonly stored as coal dumps and slurry dams and emits CO2 as it is being stored. By utilising coal fines

as a fuel source, emissions will be reduced.

2.3.6 National Climate Change Response Policy, 2011

South Africa’s National Climate Change Response Policy (NCCRP) establishes South Africa’s approach to

addressing climate change, including adaptation and mitigation responses. The NCCRP formalises

Government’s vision for a transition to a low carbon economy, through the adoption of the ‘Peak, Plateau

and Decline’ (PPD) GHG emissions trajectory whereby South Africa’s emissions should peak between 2020

and 2025, plateau for approximately a decade, and then decline in absolute terms thereafter, and based

on this the country has pledged to reduce emissions by 34% and 42% below Business As Usual (BAU)

emissions in 2020 and 2025, respectively.

As an integral part of the policy, a set of near-term priority flagship programmes will be implemented to

address the challenges of climate change. Amongst others, the Waste Management Flagship Programme

was identified by the government and will be led by the DEA. This flagship programme will “establish the

GHG mitigation potential of the waste management sector”. This will include investigating the generation,

capture, conversion and/or use of methane emissions amongst others. This data will in turn be used to

compile and implement a detailed Action Plan specifically related to the reduction of GHG emissions

associated with waste.

The Department of Environmental Affairs (DEA) released a draft National Adaptation Strategy (NAS) for

South Africa in November 2016 for comment. The NAS is intended to:

» Act as the primary guidance document for climate change adaptation efforts in South Africa,

providing direction for all levels of government.

» Inform national, provincial and local development planning.

» Help gauge the degree to which development initiatives at different levels of government integrate

and reflect critical climate change adaptation priorities, and thus inform levels of resource allocation

from revenue streams related to climate change resilience.

» Support South Africa in meeting its international obligations by demonstrating progress on climate

change adaptation, and also serve as South Africa’s national adaptation plan.

» Guide stronger coherence and coordination on climate change adaptation between different

institutions and levels of government.




The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site.

It is expected that the removal of individual boilers will reduce emissions within the industrial area. The CFB

boiler will utilise coal fines which are commonly stored as coal dumps and slurry dams and emits CO2 as it is

being stored as a fuel source. By utilising coal fines as a fuel source, emissions will be reduced.

2.3.7 Industrial Policy Action Plan (IPAP), 2016 / 2017 – 2018 / 2019

The Industrial Policy Action Plan (IPAP) 2016/2017 – 2018/2019 represents a significant step forward in

scaling up the country’s efforts to promote long-term industrialisation and industrial diversification. It has

been recognised that the Southern African region is fast transforming into an oil and gas jurisdiction led by

major on and offshore gas finds in Mozambique, Tanzania, Botswana and Namibia. From a South African

perspective, the scale of the natural gas find in neighbouring Mozambique (estimated at between 200-

250tcf) is of particular significance. Accordingly, the plan states that a key industrial growth path is gas-

based industrialisation (Department of Trade and Industry, 2016).

In this quest, the development of the long-term strategic framework to leverage the opportunities

presented by regional oil and gas resources was created. The core purpose of this intervention is to put in

place the necessary institutional infrastructure to implement the long-term strategic programme and

maximise the multiplier effects of recently discovered and potentially forthcoming Southern African natural

gas resources (Department of Trade and Industry, 2016).

As the industrial growth for the country has been identified as being gas-based, the development of the

Clayville Thermal Plant utilising natural gas and/or syngas as a fuel resource, will assist in achieving the

goals of the IPAP.

2.4 Provincial Policy and Planning Context

The following provincial policies are considered to be relevant to the development of the Clayville Thermal

Plant.

2.4.1. Gauteng Provincial Environmental Management Framework (GPEMF) 2014

The Provincial EMF was gazetted on 22 May 2015 and replaces all other environmental management

frameworks in the province. The objective of the GPEMF is to guide sustainable land use management

within the Gauteng Province. The GPEMF provides a strategic and overall framework for environmental

management in Gauteng while aligning sustainable development initiatives with the environmental

resources, developmental pressures, as well as the growth imperatives of Gauteng.

Key objectives identified within the GPEMF are:

» To facilitate the optimal use of current industrial, mining land and other suitable derelict land for the

development of non-polluting industrial and large commercial developments.

» To protect Critical Biodiversity Areas (CBAs as defined in C-Plan version 3.3) within urban and rural

environments.

» To ensure the proper integration Ecological Support Areas (ESAs as defined in C-Plan version 3.3) into

rural land use change and development.




» To use ESAs as defined in municipal bioregional plans in spatial planning of urban open space corridors

and links within urban areas.

» To focus on the sustainability of development through the implementation of initiatives such as:

Energy efficiency programmes, plans and designs;

Waste minimisation, reuse and recycling;

Green infrastructure in urban areas; and

Sustainable Drainage Systems (SuDS).

The development of the Clayville Thermal Plant will facilitate the optimal use of current industrial land, and

contribute towards the sustainability of developments through waste minimisation, reuse and recycling as

outlined in the GPEMF.

The GPEMF has divided the Gauteng Province into five Environmental Management Zones (EMZs) (refer to

Figure 2.1). The purpose of these zones is to identify specific planning and policy measures associated with

a specific zone to achieve the development objectives of the zone. The GPEMP identifies appropriate,

inappropriate and conditionally compatible activities in various Environmental Management Zones in a

manner that promotes proactive decision-making.

The Clayville Thermal Plant falls within Zone 5, which is the industrial and commercial development focus

zone. The purpose of Zone 5 is to streamline environmental impact management related to non-polluting

industrial and large-scale activities in areas that are already being used for this purpose by identifying

certain listed activities which do not require Environmental Authorisation. A notice to exempt these

activities from environmental authorisation was adopted on 22 May 2018. The Clayville Thermal Plant does

however not trigger any activities which are exempted from applying for Environmental Authorisations.




Figure 2.1: Environmental Management Zones within Gauteng (obtained from the Gauteng

Environmental Management Framework, 2014).

2.4.2. Gauteng Integrated Waste Management Policy

The Gauteng Province has the greatest industrial density which also generates the largest amount of

waste. The Gauteng Department of Agriculture, Conservation and Environment (GDACE) recognised the

need for a policy which will ensure that waste is effectively managed while preserving human health and

the environment. The Gauteng Integrated Waste Management Policy, 2006 has been adopted in

response to this need. The goal set out by the Gauteng IWM Policy is to “set out the vision, principles and

strategic goals and objectives that the Gauteng Provincial Government will apply to achieve integrated




and environmentally-sustainable waste management in the Province, thereby ensuring that its obligations

and duties in terms of the South African Constitution and other relevant requirements are effected”.

The Gauteng IWM Policy aims to address issues, problems and needs of the Gauteng Province in terms of

waste and embraces co-operative environmental governance by establishing decision-making principles

on factors that affect the environment including:

» Sustainable development;

» Integrated Environmental Management using the Best Practical Environmental Option;

» The Polluter Pays Principle;

» The Cradle to Grave Responsibility;

» The Precautionary Principle; and

» The involvement of Interested and Affected Parties (IAPs) and stakeholders in environmental decision-

making.

Wastewater produced by Astral Foods are currently being disposed into the municipal sewage system.

The Clayville Thermal Plant will treat wastewater from Astral Foods to a potable standard. The water will

then be piped back to Astral Foods to be reused in their processing plant.

2.4.3. Review of the 2009 Gauteng Air Quality Management Plan (AQMP)(2018)

The Gauteng Department of Agriculture and Rural Development (GDARD) compiled the first provincial Air

Quality Management Plan in 2009 in accordance with Section 15(1) of the National Environmental

Management: Air Quality Act (Act No. 39 of 2004). The Plan identifies seven key air quality management

issues in the province and intervention strategies to address each of these issues. Considering physical

changes to the environment and multiple air quality management activities in the province, the GDARD

have recognised the need to review the 2009 AQMP. The overall objective for the review of the Gauteng

AQMP is to establish the status of air quality in the province and to develop an AQMP with objectives to

ensure prevention of deterioration and improvement in air quality in the province.

The following goals are set out in the Plan:

» Goal 1: Emissions in Gauteng are reduced to improve ambient air quality to comply with the NAAQS.

» Goal 2: The AQMP is incorporated into provincial policy and planning.

» Goal 3: GDARD has the necessary skills to implement the AQMP.

» Goal 4: GDARD has the necessary systems and tools to implement the AQMP.

» Goal 5: GDARD has the necessary incentives to implement the AQMP.

» Goal 6: AQM in Gauteng is supported by participatory decision making.

» Goal 7: Awareness of AQM in Gauteng is inclusive and effective.

The AQMP includes an Implementation Plan which provides strategic input to the Annual Performance

Planning (APP) of executing departments and of other stakeholders and focusses on specific aspects for

each goal. The implementation of the AQMP therefore depends on the Air Quality Directorate and the

input and participation of other stakeholders. The Implementation Plan furthermore provides indicators

which are designed to be easily interpreted and offer a means of measuring progress with implementation

and reporting on progress.




The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s site.

It is expected that the removal of individual boilers will reduce emissions within the industrial area and

therefore in line with Goal 1 of the AQMP.

2.5 Local Policy and Planning Context

The strategic policies at the district and local level1 have similar objectives for the respective areas, namely

to accelerate economic growth, create jobs, uplift communities and alleviate poverty. As detailed below,

the development of the Clayville Thermal Plant is considered to align with the aims of these policies, even if

contributions to achieving the goals therein are only minor.

2.5.1. Ekurhuleni Metropolitan Municipality Spatial Development Framework (MSDF), 2015

The purpose of the Ekurhuleni Metropolitan Municipality (EMM) SDF of 2015 is to provide the first step

towards guiding future spatial development in Ekurhuleni to achieve a more sustainable metropolitan city

structure, which can lead economic and social development in Gauteng (EMM, 2015).

The MSDF recognises that development is multi-facetted with various sectors such as the economic, social,

physical and institutional sectors that influence each other and provides and overview of these sectors

and how they impact on the spatial development of Ekurhuleni. Considering the economic trends and

tendencies of Ekurhuleni, it is evident that the area is characterised by growing unemployment and

increasing job losses. Approximately 58% of the population in Gauteng is economically active of which the

highest unemployment rate are currently found in the Ekurhuleni Metropolitan Area. The Clayville Thermal

Plant will result in the creation of job opportunities within Ekurhuleni.

The MSDF also identifies seven major concentrations of industrial activity which includes approximately 20

industrial areas. Amongst these are the Olifantsfontein and Clayville industrial areas which consist

predominantly of heavy industrial activities. The Clayville Thermal Plant will be situated within the centre of

the Clayville industrial area and will be consistent with the existing industrial character of the area.

2.5.2 Ekurhuleni Growth and Development Strategy, 2025

The Ekurhuleni Metropolitan Municipality Growth and Development Strategy (EMM GDS) takes guidance

from the NDP and responds thereto by including programmes that would address the results planned in

the NDP, and also the unique challenges Ekurhuleni is facing on its development trajectory (IDP & SDBIP

2013/2014). Therefore, the purpose of the EMM GDS is to translate the NDP into a detailed implementation

plan at a metropolitan level.

The EMM GDS identifies key focus areas within the Metropolitan Municipality as follows:

» The local economy requires a greater degree of sustainable diversification;

1 The uThungulu District Municipality was renamed King Cetshwayo District Municipality in July 2016.




» As elsewhere in South Africa, unemployment is high, and policies to promote labour absorption and job

creation will be of crucial importance to the future of the city;

» The improvement of skills levels to attract and support local economic growth is of critical importance;

» Ekurhuleni is a gateway into Africa and opportunities for tourism promotion and development locally

should be taken advantage of;

» No city can survive without new investment (in physical, economic and social infrastructure) and

investment promotion and facilitation will therefore be a key focus area; and

» The greatest portion of the wealth in the city is still in the hands of a small elite, and broad-based

economic transformation as well as entrepreneurial activity will therefore be promoted at every

opportunity.

The proposed project will result in the creation of job opportunities, sustainability, and strategic

infrastructure for social and economic growth which will contribute, albeit to a limited extent, towards

reducing poverty and inequality in Gauteng. This development will therefore assist the municipality in

achieving the aims of the EMM GDS to some extent.

2.5.3 Ekurhuleni Metropolitan Municipality Integrated Development Plan (IDP), 2013/2014

The Ekurhuleni Metropolitan Municipality IDP is the principal strategic planning instrument which guides and

informs all planning, budgeting, management and decision making processes in the municipality and

recognises the importance of stakeholder involvement. The purpose of the IDP is to identify key

development priorities; formulate a clear vision, mission and values for the municipality; formulate

appropriate strategies; develop the appropriate organisational structure and systems to realise the vision

and mission; and align resources with the development priorities (EMM, 2013).

The development of the Clayville Thermal Plant will create employment opportunities which will contribute

towards strengthening the current socio-economic conditions of the area, as well as improving the

standard of living.

2.5.4 Ekurhuleni Metropolitan Municipality Regional Spatial Development Framework (RSDF): Region B,

2015

The Ekurhuleni Metropolitan Municipality’s Regional Spatial Development Framework (RSDF) has been

developed in response to spatial issues and challenges experienced within the Municipality and to provide

direction in terms of development within the Municipality. The RSDF divided the Municipality into six regions

to provide a better understanding of the spatial structure of each region, making it easier to respond to

critical issues, to plan appropriately and to develop an SDF that will be practical and implementable.




The project site falls within Region B as defined within the RSDF. The vision of the Municipality for Region B

includes major urban growth due to the proximity to the OR Tambo International Airport and its expected

growth as an aerotropolis2. As part of this vision, the Municipality proposed to:

» Unleash areas for urban development;

» Identify areas where selective densification is required;

» Identify areas of transition; and

» Capitalise on the untapped agricultural potential of the region.

Although the Municipality has a vision for major urban growth within Region B, the RSDF categorised the

Olifantsfontein/Clayville area as one of five focus areas for industrial and commercial development. The

other areas include the R21 development corridor, Sebenza, Eastleigh and Chloorkop.

2.6 International Policy

2.6.1 United Nations Framework Convention on Climate Change (UNFCCC) and Conference of the Party

(COP) 21 – Paris Agreement

Climate change is one of the major global challenges of the 21st century that requires global response.

The adverse impacts of climate change include persistent drought and extreme weather events, rising sea

levels, coastal erosion and ocean acidification, further threatening food security, water, energy and

health, and more broadly efforts to eradicate poverty and achieving sustainable development.

Combating climate change would require substantial and sustained reductions in greenhouse gas (GHG)

emissions, which together with adaptation, can limit climate change risks. The convention responsible for

dealing with climate change is the United Nations Framework Convention on Climate Change (UNFCCC).

The UNFCCC was adopted in 1992 and entered into force in 1994. It provides the overall global policy

framework for addressing the climate change issue and marks the first international political response to

climate change. The UNFCCC sets out a framework for action aimed at stabilizing atmospheric

concentrations of GHGs to avoid dangerous anthropogenic interference with the climate system.

The UNFCCC has established a variety of arrangements to govern, coordinate and provide for oversight of

the arrangements described in the documentation. The oversight bodies take decisions, provide regular

guidance, and keep the arrangements under regular review in order to enhance and ensure their

effectiveness and efficiency. The Conference of Parties (COP), established by Article 7 of the Convention,

is the supreme body and highest decision-making organ of the Convention. It reviews the implementation

of the Convention and any related legal instruments, and takes decisions to promote the effective

implementation of the Convention.

COP 21 was held in Paris from 30 November to 12 December 2015. From this conference, an agreement to

tackle global warming was reached between 195 countries. This Agreement is open for signature and

2 According to the Ekurhuleni Metropolitan Municipality’s RSDF for of 2015 for Region B, aerotropolis refers to a new urban form that

has commenced with evolving around airports. It consists of the traditional metropolis made up of a central city and its rings of

commuter heavy suburbs.




subject to ratification, acceptance or approval by States and regional economic integration organisations

that are Parties to the Convention from 22 April 2016 to 21 April 2017. Thereafter, this Agreement shall be

open for accession from the day following the date on which it is closed for signature. The agreement can

only enter into force once it has been ratified by 55 countries, representing at least 55% of emissions.

This Agreement, in enhancing the implementation of the Convention, including its objective, aims to

strengthen the global response to the threat of climate change, in the context of sustainable

development and efforts to eradicate poverty, including by:

(a) Holding the increase in the global average temperature to well below 2 °C above pre-industrial levels

and to pursue efforts to limit the temperature increase to 1.5 °C above pre-industrial levels, recognising

that this would significantly reduce the risks and impacts of climate change.

(b) Increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience

and low GHG emissions development, in a manner that does not threaten food production.

(c) Making finance flows consistent with a pathway towards low GHG emissions and climate-resilient

development.

In order to achieve the long-term temperature goal set out in Article 2 of the Agreement, Parties aim to

reach global peaking of GHG emissions as soon as possible, recognising that peaking will take longer for

developing country Parties, and to undertake rapid reductions thereafter in accordance with the best

available science, so as to achieve a balance between anthropogenic emissions by sources and

removals by sinks of GHGs in the second half of this century, on the basis of equity, and in the context of

sustainable development and efforts to eradicate poverty.

The Paris Agreement requires all Parties to put forward their best efforts through “nationally determined

contributions” (NDCs) and to strengthen these efforts in the years ahead. This includes requirements that

all Parties report regularly on their emissions and on their implementation efforts. In 2018, Parties will take

stock of the collective efforts in relation to progress towards the goal set in the Paris Agreement and to

inform the preparation of NDCs. There will also be a global stocktake every 5 years to assess the collective

progress towards achieving the purpose of the Agreement and to inform further individual actions by

Parties.

South Africa signed the Agreement in April 2016, and ratified the agreement on 01 November 2016. The

Agreement was assented to by the National Council of Provinces on 27 October 2016, and the National

Assembly on 1 November 2016. The Agreement came into force on 04 November 2016, thirty days after

the date on which at least 55 Parties to the Convention accounting in total for at least an estimated 55%

of the total global greenhouse gas emissions have deposited their instruments of ratification, acceptance,

approval or accession with the Depositary.

The development of the Clayville Thermal Plant will eliminate the need for off-takers to produce their own

steam using small boilers located on the off-taker’s site within the Clayville industrial area. It is expected

that the removal of individual boilers will reduce emissions within the industrial area. Furthermore, the CFB

boiler will utilise coal fines which is considered to be a waste by-product from coal mining as a feedstock.

These coal fines are commonly stored as coal dumps and slurry dams and emits CO2 as it is being stored.

By utilising this waste by-product as a fuel source, emissions will be reduced.



Project Description Page 28

CHAPTER 3 PROJECT DESCRIPTION



This chapter of this final EIA report includes the following information required in terms of Appendix 3:



3(d)(ii) a description of the scope of the proposed

activity, including a description of the associated

structures and infrastructure related to the development.

A description of the Clayville Thermal Plant is included

within Section 3.4.

3(f) a motivation for the need and desirability for the

proposed development, including the need and

desirability of the activity in the context of the preferred

development footprint within the approved site as

contemplated in the accepted scoping report.

The need and desirability of the development of the

Clayville Thermal Plant within the project site is included

in Section 3.2.

3(g) a motivation for the preferred development

footprint within the approved site as contemplated in

the accepted scoping report.

A motivation for the preferred development footprint

within the project site is included in Section 3.3.2.

3(h)(i) details of the development footprint considered. The details of the development footprint are included in

Section 3.4, Table 3.1.

3(h)(ix) if no alternative development footprints for the

activity were investigated, the motivation for not

considering such.

No development footprint alternative were considered.

The motivation for not considering a footprint alternative

is included in Section 3.3.2.

3(h)(x) a concluding statement indicating location of

the preferred alternative development footprint within

the approved site as contemplated in the accepted

scoping report.

A concluding statement for the preferred development

footprint within the project site is included in Section

3.3.2.

3.2 Need and Desirability for the Clayville Thermal Plant

There are a number of industries within the Clayville Industrial area which make use of steam in various

processes. Some of these industries currently make use of coal-fired boilers, diesel, HFO or gas on their site

to produce steam. The central steam generation facility will make use of CFB technology which can utilise

a number of fuel sources (including waste coal fines and gas), and which will be more efficient. A central

steam generation facility (or thermal plant) in the Clayville industrial area is considered to be desirable as a

result of:

» Zoning of the site;

» Utilising a more efficient technology to raise steam for various purposes compared to existing

technologies currently being used in the Clayville industrial area, thus reducing overall air emissions in

the industrial area;

» Utilising a range of fuel sources (including waste coal fines and gas) for the production of steam,

reducing reliance on heavy fuels and lower efficiency small boilers;

» Availability of wastewater for treatment and use within the plant and other industrial companies in the

area; and




» Providing employment opportunities.

Zoning of the site:

The proposed development site is zoned industrial and is located within a formal industrial area. The

Clayville Thermal Plant also falls within Zone 5 of the GPEMG (2014), which is the industrial and commercial

development focus zone. The development is therefore considered to be compatible with the current

land use of the property and surrounding area, as well as with development planning for the area.

Reducing CO2 emissions:

Coal fines are typically defined as coal with a particle size below 6mm and has traditionally been

considered as waste and an unwanted by‐product in the coal mining industry. These fines have presented

a major disposal challenge to the mining industry throughout South Africa. South Africa produces

approximately 300 million tons of coal per year of which up to 20% consist of coal fines

(http://minerestoration.co.za/business-segments/coal-briquetting-project/).

These coal fines are generally stored as coal dumps and slurry dams. According to Cook and Lloyd (2012),

when coal is exposed to air, oxidation takes place until the temperature is high enough for combustion to

occur. Combustion can occur when waste coal dumps still contain sufficient coal matter and therefore

these coal dumps can emit CO2. These dumps and slurry dams become a liability to mines when

rehabilitation upon mine closure is required. The coal fines also have a fairly low calorific value and

cannot be utilised for blending coal or by Eskom for power generation purposes within their current power

stations. As CFB boilers are able to utilise a variety of fuel sources (including coal fines), this provides a

viable fuel source for the proposed project. By using coal fines as part of the feedstock for the thermal

plant, the project converts a mining liability into a revenue stream.

In addition, several of the potential off-takers within the Clayville industrial area already make use of coal-

fired boilers on their site to produce steam to use in various direct and indirect processes within their plants.

Other fuel sources used by off-takers include diesel, HFO and gas. The installation of the Clayville Thermal

Plant will eliminate the need for small boilers on the off-taker’s sites and will therefore reduce different

emission sources from the various boilers within the area.

Furthermore, the CFB boiler combustion provides operators with greater flexibility in burning a range of

coal and other fuels without compromising efficiency and at the same time reducing emissions. By utilising

not only coal fines as a feedstock for the CFB boiler, but also natural gas and/or syngas, less coal and

heavy fuels will be required and therefore an overall decrease in emissions is expected within the Clayville

industrial area.

Recycling of wastewater:

Astral Foods, a poultry producer located adjacent to the project site, produces large volumes of

wastewater. The Clayville Thermal Plant will be recycling 6 000kl of Astral Foods’ (Festive’s) effluent

wastewater per day during the operation phase. The water used by Astral is currently supplied by the

municipality on a daily basis. The recycled water will be of a potable standard and will be piped back to

Astral Foods to be used in their processing plant. This will result in a reduction of wastewater being

disposed of to the municipal system, thereby reducing the pressure on these systems and impacts on the

environment. This will also decrease demand to the municipality for the supply of water to the largest

industrial user in the area.




Employment opportunities:

Service delivery, infrastructure development, socio-economic development, poverty and unemployment

have been identified as key focus areas for the Ekurhuleni Metropolitan Municipality. The Ekurhuleni

Growth and Development Strategy, 2025 acknowledges the high unemployment rate in the municipality

and recognises that labour absorption and job creation will be of crucial importance to the future of

Gauteng.

The development of the Clayville Thermal Plant (including the wastewater treatment plant) would

contribute towards employment creation, both directly and indirectly. While only 14-25 job opportunities

are expected to be created during the operation of the plant, this is expected to contribute somewhat

towards reducing unemployment and poverty levels within the municipality.

3.3 Project Alternatives

In accordance with the requirements outlined in Appendix 2 of the EIA Regulations 2014 (as amended),

the consideration of alternatives including site, activity, technology, as well as the “do-nothing” alternative

should be undertaken. Therefore, the identification of alternatives is a key aspect of the success of the EIA

process. In relation to a proposed activity “Alternatives” means different ways of meeting the general

purposes and requirements of the proposed activity. The following sections address this requirement in

terms of the project in question.

3.3.1 Site Alternatives

A site selection process was undertaken by Bellmall Energy Project 325 to locate and identify potential sites

for the development of the thermal plant. Due to the nature of the development, the location of the

project site is largely dependent on several factors which includes:

» Location in relation to potential off-takers;

» Size of the property to facilitate a thermal plant;

» Avaialbility of the site for development.

» Proximity to a coal resource;

» Proximity to a gas resource (natural gas);

» Availability of wastewater;

» Zoning of the property; and

» Accessibility to major road infrastructure.

Based on the above criteria, Bellmall Energy Project 325 identified the Clayville Industrial area as the most

suitable area for the development of the Central Thermal Plant. Several potential sites in the Clayville

industrial area were considered for the development of the proposed thermal plant. These include:

» Erf 432 (Festive / Astral Foods) situated east of the project site;

» Erf 457;

» Erf 459;

» Erf 472 and Erf 469 located north of the project site;

» Erf R4316 (CloverSA) situated north west of the project site; and

» Portion 12 of Erf 508.




The viability or feasibility of the use of the land parcels was further considered by the project developer.

The following was concluded:

» Erf 432 was eliminated from the process due to the property being too small to accommodate the

footprint of the Clayville Thermal Plant. Furthermore, there is also the possibility that Astral Foods would

expand their operations and would then require Erf 432.

» Erf R4316 was eliminated due the property being too small to accommodate the Clayville Thermal

Plant.

» Erf 472/469 was eliminated as an agreement could not be reached in purchasing the property.

» Erf 457, Erf 459 and Portion 12 of Erf 508 were identified as the most suitable. This is referred to as the

project site within this report and has been considered within this EIA process.

The project site adheres to the characteristics considered in the site selection process in the following ways:

» The project site is considered to be large enough to accommodate the central plant and

infrastructure associated with the plant.

» The project site is located within the centre of the Clayville industrial area, and is surrounded by

potential off-takers. Due to the close proximity of off-takers to the site, steam reticulation will be more

efficient compared to off-takers situated further away. This also leads to a smaller network of steam

pipes.

» An existing Sasol pipeline is situated along Spanner Road which is directly adjacent to the western

boundary of the project site.

» A major factor which has influence on the development of a thermal plant that utilises coal fines is the

availability of a viable coal fine resource. The location of coal resources and its associated transport

considerations therefore played a significant role in determining the broader regional area within

which a thermal plant utilising coal fines as a feedstock may be developed. Mines in the Delmas and

Middelburg areas were selected as preferred sources due to the distance between the thermal plant

and the coal fine resource.

» The project site is located adjacent to Astal Foods which can supply the thermal plant with sufficient

volumes of wastewater.

» Accessibility to the site is possible via the N1 and N14. These national routes connect to various other

national routes within the country allowing for widespread accessibility. Access to the site is also

possible via the regional road (R21), which is located approximately 1.9km to the east of the site. The

R562, also known as Olifantsfontein Road located south of the site connects to the R21 and to Old

Pretoria Main Road located to the west and can be used for access to the site.

» The project site is zoned as Industrial 1.

» All three properties are available for purchase by the project developer.

The Clayville Thermal Plant project site was the only site identified as being technically feasible and viable

to take forward to further investigation from an environmental perspective.




3.3.2 Layout Alternatives

The project site was subjected to an environmental screening and fatal flaw analysis prior to the EIA

process in order to identify potential fatal flaws, impacts and risks associated with the activity and how

these activities will impose on the project site and surrounding areas through the life of the activity. The

Environmental Screening and Fatal Flaw Analysis approach served as a site risk assessment tool from an

environmental acceptability perspective – that is, a process to highlight or red-flag potential

environmental issues of concern within the project site prior to initiating a full EIA process. This study has

been informed by specialist screening studies and sensitivity mapping. It was concluded that the area

surrounding the project site is already disturbed by other industrial uses and infrastructure and that no

environmental fatal flaws have been identified to be associated with the thermal plant. The Clayville

Thermal Plant project site was the only site identified as being technically feasible and viable to take

forward to further investigation in support of an application for authorisation by way of EIA. This is referred

to as the preferred project site throughout this EIA Report.

A typical mitigation hierarchy was utilised for the consideration of the suitability of the site for the proposed

project during the EIA process.

1. First Mitigation: avoidance of adverse impacts as far as possible by use of preventative measures.

2. Second Mitigation: Further minimisation or reduction of adverse impacts.

3. Third Mitigation: remedy or compensation for adverse residual impacts, which are unavoidable and

cannot be reduced further.

Through the Scoping Phase a number of potential sensitive features surrounding the project site have been

identified which could be affected by the development of the Clayville Thermal Plant. No sensitivities

were identified within the project site itself. The following is of note:

» According to the Gauteng C-Plan, an ESA is situated adjacent to the western boundary of the project

site and a CBA is located south of the project site. No ESA or CBA have been identified within the

project site.

» The downwind sector from the thermal plant is predominantly east-southeast to west-southwest of the

facility, i.e. downwind under the prevailing west-northwest to east-northeast. There are two residential

areas in close proximity to the project site and includes Clayville East (1.1km north east) and Tswelapele

(1.8km to the west). A risk exists that emissions from the Clayville Thermal Plant may result in ambient

concentrations of the air pollutants in the nearby residential areas that exceeds the health based

NAAQS. The project site is located in an industrial area which provides a buffer between the thermal

plant and the residential areas.

No areas of environmental sensitivity or no-go areas which would affect the positioning of the facility within

the broader site were identified through the Scoping Phase studies. Therefore, the most suitable layout of

the facility from a technical perspective was determined (refer to Figure 3.1). This is the layout considered

within this EIA Report. No other layout alternatives are considered.




Figure 3.1: Map showing the layout for the Clayville Thermal Plant and associated infrastructure located within Erf 457, Erf 459 and Portion 12

of Erf 508 (refer to Appendix J for A3 maps).




3.3.3 Technology Alternatives

The generation of stream by utilising CFB boiler technology is considered to be an advanced conversion

technology that has the ability to produce a clean, high-calorific value steam from a wide variety of fuel

streams (e.g. coal and gas in this instance). The development of the Clayville Thermal Plant utilising a CFB

boiler has been identified by Bellmall Energy Project 325 as the most feasible technology alternative for the

generation of steam within the Clayville industrial area. The use of this technology has been considered as

the most efficient, economical and environmentally friendly technology compared to other technologies

available. This technology is considered to be a ‘tried and tested’ technology due to the numerous similar

plants being constructed and successfully operated internationally. As such, no steam generation

technology alternatives are being considered for this development within the Clayville industrial area.

3.3.4 Cooling Technology alternatives

Dry Cooling

Dry cooling by air cooled condensers (ACC) consists of large sections of finned air cooled heat

exchangers (with mechanical draft), and the exhaust steam passes through the heat exchangers forming

condensate. This arrangement uses no cooling water, and therefore requires no makeup for evaporation

losses. ACC cooling can considerably reduce the total make-up water demand, leaving only the process

consumption and service water as major users, but is limited by its sensitivity to ambient temperature. This is

the cooling technology that is preferred for the development of the Clayville Thermal Plant, due to the

location of the site which will not be able to house the extensive piping required for once-through cooling.

This is also consistent with the Department of Water and Sanitation requirements, which require a reduction

in use of water. Therefore only dry-cooling technology is considered within this EIA process.

3.3.5 The ‘Do-Nothing’ Alternative

The “do-nothing” alternative is the option of not constructing the proposed Clayville Thermal Plant. This

alternative is assessed within Chapter 6 of this report.

3.4 Description of the Proposed Project

Bellmall Energy 325 (Pty) Ltd proposes the development of the Clayville Thermal Plant on a site located

near Olifantsfontein within the Clayville industrial area in Gauteng Province. The thermal plant (also

referred to as the central plant) is proposed on Erf 457, Erf 459 and Portion 12 of Erf 508 which is situated

within the Ekurhuleni Metropolitan Municipality. The area under investigation is approximately 1.76ha in

extent (refer to Table 3.1).

Table 3.1: Project Site Details

Province Gauteng Province

Municipality Ekurhuleni Metropolitan Municipality

Ward number(s) 1

Nearest Town Clayville East (~1.1km east), Tswelapele (~1.8km west) and Clayville

(~1.95km north west)

Farm Names and Numbers Erf 457

Erf 459




Portion 12 of Erf 508

SG 21 Digit Code

T0JR00360000045700000

T0JR00360000045900000

T0JR00360000050800012

Current Zoning Industrial Use – The affected properties are located within the Clayville

Industrial Area and are zoned as Industrial 1.

Site Extent

Erf 457 0.74ha

Erf 459 0.21ha

Portion 12 of Erf 508 0.81ha

TOTAL 1.76ha

Site Co-ordinates

Latitude: Longitude:

Northern-most extent 25°58’8.65’’ S 28°14’5.71’’ E

Eastern-most extent 25°58’10.33’’ S 28°14’7.01’’ E

Southern-most extent 25°58’15.93’’ S 28°13’59.47’’ E

Western-most extent 25°58’14.26’’ S 28°13’58.17’’ E

Centre point 25°58’12.35’’ S 28°14’ 2.40’’ E

The construction of a thermal plant utilising a Circulating Fluidised Bed (CFB) boiler will provide steam to off-

takers in the industrial area. Fuel feedstock will be a combination of coal fines, (i.e. waste coal from coal

mines), syngas and/or natural gas. The following is relevant regarding fuel supply and storage:

» Coal fines will be sourced from 2-3 mines located in the Delmas and Middelburg areas and will be

transported to the project site via road transport and stored on-site. Coal fines from the immediate

area will be procured should a source become available.

» Natural gas will be obtained via an existig Sasol pipeline situated along Spanner Road in the Clayville

industrial area. No natural gas will be stored on-site but will be supplied to the central plant as

required.

» Syngas will be sourced from the Bellmall Energy Syngas Plant situated at remote locations and will be

transported to site via trucks.

» 660 Tons / day of fuel will be delivered to the site by truck. There will be 22-25 trucks per day, 32 metric

tons each (truck and trailer configuration).

» Fuel Storage will be on the same site as the Central Site. This will entail 3 days capacity, i.e. 2000 tons.

The thermal plant will combine high-efficiency combustion of various solid fuels with low emissions, even

when burning fuels with completely different calorific values simultaneously. The steam plant will generate

up to 240 tons of steam per hour which will be an equivalent of up to 60 MWe.

Potential process steam off-takers include (refer to Figure 1.3 for a map indicating where the off-takers are

situated within the Clayville industrial area):

» Aspen;

» Astral Foods;

» Clover SA;

» Sasko; and

» Nestle R&R Ice cream.




3.4.1 Infrastructure

The main infrastructure associated with the facility includes the following:

» CFB Boiler,

» Steam supply pipes from the central plant to various off-takers within the Clayville industrial area,


area,

» Exhaust stack located adjacent to the central plant,

» Condenser on site for the conversion of steam back to water,

» Wastewater treatment plant with a capacity of 6 000kl per day for the disinfection of water,


Clayville industrial area.

» Holding tanks for the storage of water,

» Storage of diesel within permanent immobile liquid tanks,

» Silos for the storage of bottom ash, fly ash and limestone,



» Feedstock holding and processing area, and

» Maintenance building / office and control room.

Table 3.2 provides details of the proposed thermal plant, including the main infrastructure and services.

Table 3.2: Details of the Clayville Thermal Plant and associated infrastructure

Component Description/ Dimensions

Steam Generating

capacity

240 tons of steam per hour ( equivalent of up to 60MWe)

Proposed technology Thermal Plant utilising Circulating Fluidised Bed (CFB) boiler technology

Stack dimensions Exhaust stack height will be ~55m in height with a diameter of ~2m.

Feedstock holding area

(coal fines) (area where

coal fines will be

temporarily stored before

being processed)

» Total area of ~1859m2

» The coal fines will be stored in a purpose made dome with removable covers to the

top of the tank. Size of tanks to be 25m x 45m.

» The height of the stockpile will approximately be 20m.

» A maximum of 2600m3 per day of coal fines will stored on-site during the operation

phase.

Feedstock holding area

(syngas) (area where

syngas will be temporarily

stored before being

processed)

» Forty 22 650 litre gas cylinders (made of steel and/or stainless steel)

» 112,720 GJ of Syngas will be stored in cylinders during the operation phase (3 day

supply).

Feedstock processing

area (where feedstock

will be processed before

being fed into the CFB

boiler, if required)

» ~893m2

Fuel storage » Storage of diesel will be required for a backup generator. Less than 80m³ of diesel

will be stored in a tank during operation.

» Other dangerous goods will also be stored and handled on site, including





flammable oils (i.e. lubricant oils, solvents etc.) and chemicals for the water

treatment plant.

Gas supply » Natural gas will not be stored on site but will be supplied as required via the Sasol

gas pipeline situated along Spanner Road in the Clayville industrial area.

» Syngas will be sourced from the Bellmall Energy Syngas Plant situated at remote

locations and will be transported to site via trucks.

Pipeline (steam pipeline

to different off-takers

within the Clayville

industrial area)

» Length of the pipeline will be 3,200m.

» Internal diameter will be 300mm.

Storage of bottom ash » Will be stored in a silo (5m diameter x 18m high)

» 1-3 tonnes of bottom ash is expected to be produced an hour, which will be

removed form site on a daily basis.

Storage of fly ash » Will be stored in a silo (10m diameter x 24m high)

» 3-12 tonnes of fly ash is expected to be produced an hour, which will be removed

form site on a daily basis.

Storage of limestone » Will be stored in a silo (5m diameter x 18m high)

» The limestone consumption is expected to be 43 800 tonnes per year.

Wastewater treatment

plant

» The footprint of the wastewater treatment plant will be ~1218,69m2. No wastewater

will be discharged. The treated wastewater will be returned to the off-taker. The

capacity of the plant will be 6 000 m³ per day.

» Waste from the treatment process can be either used in a biogas plant or used for

fertilizer.

Access roads » Approximately 341m in length and 4m wide

Site access » Main access to the project site will be via existing roads - Spanner Road adjacent

to the western boundary of the project site and Industrial Road adjacent to the

eastern boundary of the project site.

Services required » Waste disposal - all waste material generated from the development, will be

collected by a contractor and the waste will be disposed of at a licensed waste

disposal site off site. This service will be arranged with the municipality when

required.

» Wastewater utilised in the central plant will be by disposed of by means of

evaporation by utilising excess heat from the boiler. The wastewater will be

transferred across the heated coils and form steam which will then evaporate.

» Sanitation – during construction, chemical toilets will be used. All sewage waste will

be collected by a contractor to be disposed of at a licensed waste disposal site.

This service will be arranged with the municipality when required. During operation,

the facility will be connected to the municipal sewer system.

» Water – Water is to be sourced from the Ekurhuleni Metropolitan Municipality Water

Works during the construction phase. The Clayville Thermal Plant will require 100kl of

water per day for a period of up to 36 months. During the operation phase of the

thermal plant, water will be sourced from both the Ekurhuleni Metropolitan

Municipality and waste water from the off-taker’s sites. Water volumes of

approximately 50-70kl per day are expected to be required for the operation of the

project.

» Electricity: the electricity requirements for this facility are to be obtained from the

municipality. This service will be arranged with the municipality when required.





No agreement or confirmation for the above services have been obtained as yet.

3.4.2 Overview CFB Boiler Technology

The thermal plant will be designed to combine high-efficiency combustion of various solid fuels with low

emissions, even when simultaneously burning fuels with completely different calorific values. The Clayville

Thermal Plant will generate steam by utilising coal fines, syngas and/or natural gas. The steam generation

plant will generate up to 240 tons of steam per hour (an equivalent of up to 60 MWe). Figure 3.2 illustrates

how steam is typically produced at a thermal plant utilising Circulating Fluidised Bed (CFB) technology.

Figure 3.2: Illustration of a thermal plant utilising CFB technology

(http://www.brighthubengineering.com/power-plants/26549-differences-of-a-circulating-

fluidized-bed-boiler-and-a-pulverised-coal-boiler/).

The boiler furnace which is located at the bottom of the CFB boiler, contains a bed of inert material

(typically sand), which is heated and “fluidised” using jets of air. The feedstock will be spread out on the

bed to allow for combustion within the CFB boiler. Fluidised air at high pressure will lift the bed material

and the feedstock and keep it in suspension, ensuring that the gas and solid particles mix together




turbulently for better heat transfer and chemical reactions. Fuel combustion takes place in this suspended

condition at a temperature of 760˚C to 927˚C to prevent the formation of nitrogen oxide (NO). Co-

combustion is an environmentally benign method of combining excellent reliability and availability with a

potential to optimise operational costs by allowing several fuel alternatives to be used.

The combustion of coal fines results in the generation and release of various emissions (i.e. particulate

matter (including trace metals), gases (including SO2, nitrogen oxides (NOx = NO + NO2), carbon

monoxide (CO), organics (volatile organic compounds (VOC), polycyclic organic matter (PAH, PCDD,

etc.)) and trace elements (mercury, arsenic, etc.)). Fine particles of partly burned fuel, ash and bed

material are carried along with the flue gases to the upper areas of the furnace and then into a cyclone.

Ash generated by the combustion process will be removed from the boilers (i.e. bottom ash) and flue

gases (i.e. fly ash) and will be transported via trucks back to the mines from where coal fines are to be

sourced

In the cyclone the heavier particles separate from the gas and fall into the hopper. The circulating bed

material flows together with flue gas through the furnace, after which it is separated from the gas and

returned back to the lower part of the furnace with cyclones3. This ensures an even combustion

temperature profile, which is optimal for handling a wide variety of fuel properties, such as heating value,

moisture, ash content and a number of low melting point ash components. This also ensures low primary

emissions with high combustion efficiency and an excellent utilisation of additives for sulphur removal and

other special purposes. Sorbents such as limestone are injected directly into the bed of CFB boiler to

neutralise sulphur released during the combustion process, resulting in low sulphur dioxide (SO2) emissions.

Gases that are released from the combustion process accumulate in the boilers or furnaces, and are

filtered and released into the atmosphere via a smoke stack. The stack exit temperature is expected to be

100 - 130°C.

The hot gases from the cyclone pass to the heat transfer surfaces and go out of the boiler. The heat from

the combusting feedstock is absorbed by water filled tubes, in the various heater components, which line

the boiler and flue gas path, to produce steam under very high pressures. The high pressure steam will be

piped to various off-takers’ steam turbines located on the project site and low pressure steam will be piped

to various off-takers’ within the Clayville Industrial Area to be used for a variety of processes (i.e. direct

heat, process steam etc.). The pipelines is likely to be situated either within the road reserves where

possible or within the servitude at certain areas. The pipelines will be installed above ground on the off-

taker sites and below ground when installed within the road reserve and/or servitudes.

When the spent steam comes into contact with the condenser tubes, condensation of the steam takes

place, and it is converted back into a liquid state (i.e. water). The steam will be returned from the Astral

Foods’ site and other process steam off-takers to the central plant in the form of heated water. This water

will then be pumped back to the boiler at the central plant for reheating and re-used in the closed loop

system.

3 High-efficiency cylindrical cyclones constructed of membrane walls covered by a light refractory for erosion protection. No hot

expansion joints between the furnace and the cyclone are needed.




Steam generated at the central plant will also be utilised to generate power via steam turbines. In

accordance with the requirements of NERSA, individual turbines for each industrial off-taker being supplied

with steam from the central plant will be located within the central site itself. These turbines will be owned

by the various off-takers, and each turbine will be sized to each off-taker’s requirements. Should the

electricity output of an individual turbine exceed 10MW, an Environmental Authorisation (EA) in

accordance with Section 24(5) of the National Environmental Management Act (No. 107 of 1998) (NEMA),

and the 2014 Environmental Impact Assessment (EIA) Regulations (GNR 326) will be required to be

obtained. Separate applications for authorisation will be undertaken once the details of these turbines are

fully defined.

Potential steam off-takers include:

» Coca-Cola Beverages SA;

» Actom-Wilec;

» Adcock Ingram;

» Aspen;

» Astral Foods;

» Clover SA;

» Nampac;


» RSC Steel;

» Spar;

» Tiger Brands;

» Sasko; and

» Hulamin.

3.4.3 Recycling of wastewater

The proposed central plant will be developed as a Zero Liquid Effluent Discharge (ZLED) facility. All

wastewater and effluent generated during the project’s operations, as well as wastewater from Astral

Foods, will be treated via an onsite wastewater treatment plant (WWTP) and will be reused onsite and

piped back to Astral Foods for reuse.

The wastewater treatment works will include:

» Dissolved Air Flotation System (DAF)

» Static Screen

» Aerobic reactor ~3200 m3

» Filtration tank with submerged MBR modules ~500 m3

» Desludge system

» MBR Permeate holding tanks

» Reverse Osmosis 1, low pressure; 80 % recovery of MBR Permeate

» Reverse Osmosis 2, high pressure; 60 % recovery of RO1 Brine

» Disinfection of RO Permeate

» RO Permeate Storage and Transfer

Effluent wastewater will be pumped from Astral Foods via a double-channelled launder system fitted with

a channel screen to remove coarse solids (>10mm). The screened water will then be filtered by removing

finer solids (above 2mm) which is a prerequisite for the DAF and MBR reactors. Approximately 6000kl per




day of wastewater obtained from Astral Foods and will be stored in holding tanks onsite which will act as a

one day buffer required to handle the incoming flows, with auto overflow to drain the wastewater during

maintenance. The waste removed will be transported to a biogas plant. Alternatively, the waste can be

utilised as a fertiliser.

The filtered water will be subject to the DAF treatment to reduce fog’s and floats of sludge. After

treatment, the water from the DAF unit will be suitable to introduce to the MBR reactors. The MBR reactors

make use of membrane technology to reduce Chemical Oxygen Demand (COD), Biological Oxygen

Demand (BOD), Solids, Phosphorus and Nitrogen in the water. Sludge from the MBR reactors will be

treated by use of a press filter and dried along with all other solid streams.

Water from the MBR reactors will be pumped at a high pressure through tight membranes capable of

stripping constituents at a molecular level through Reverse Osmosis (RO), producing a high quality

permeate. Brine4 produced from the RO will be concentrated into disposable crystallised solids via low

energy evaporators. Ozone will be required for upstream pre-oxidation and for final disinfection of the RO

permeate.

The solids extracted from the brine will consist of the following salts:

Should the wastewater from Astral not be sufficient for the operation of the central plant at any given time

during operation, municipal water will be utilised.

3.5 Life-cycle Phases of the Thermal Plant

3.5.1 Construction Phase

Construction of the thermal plant and associated infrastructure (including the wastewater treatment

facility) is expected to take approximately 36 months. The construction activities involve the following:

4 The brine will be a in a liquid form which will be reduced to cake and crystallization form by removing most of the moisture through

an evaporator process, where the water is then recirculated into the recycling process. It is expected that 604kg of solids will be

extracted from the brine generated daily. The balance of the brine will consist of water which is reintroduced into the water

recycling system.




» Prior to initiating construction, a number of surveys will be required including, but not limited to, a

comprehensive geotechnical survey, site survey and confirmation of the thermal plant footprint.

» Access roads will need to be established onsite, specifically taking into consideration the use of

abnormal vehicles.

» Site preparation activities will include clearance of any remaining vegetation within Erf 457 and Portion

12 of Erf 508 and excavations for foundations within the project site.

» Civil works will take place, including concrete works for structures such as foundations, the thermal

plant, the stack, cooling towers and associated infrastructure.

» Mechanical and electrical work will then follow.

» Ancillary infrastructure such as guard house, admin building, workshops and a warehouse will be

established.

» As construction is completed in a certain area within the project site, the construction equipment will

be removed from that specific area.

Water requirements:

During construction, water will be sourced from the Ekurhuleni Metropolitan Municipality. It is anticipated

that a maximum of 100kl of water per day would be required during the construction phase. Water is

expected to be supplied via a direct tie-in into the municipal water supply pipeline. The development will

utilise solar water heating and heat pumps to heat any hot water requirements on-site.

Storage and Handling of Hazardous substances:

The construction phase will require the handling and storage of materials including fuel, water treatment

additives and chemicals. The combined capacity of storage containers will not exceed 80m³.

Employment:

Employment opportunities will be created during the construction phase of the project which will include

highly skilled, skilled and semi-skilled positions. Highly skilled positions will be limited. Approximately 200

employment opportunities will be created which will include ~30 unskilled and semi-skilled positions, ~150

skilled positions and ~20 skilled positions will be available over the 36 month construction phase. No

employees will reside on the project site.

3.5.2 Operation Phase

The thermal plant is expected to be operational for more than 35 years. It is anticipated that there will be

full-time security, maintenance and control room staff required at the site. Maintenance will be

undertaken when and if required. Key elements of the Operation and Maintenance plan include

monitoring and reporting the performance of the project, conducting preventative and corrective

maintenance, receiving visitors, and maintaining security of the facility.

Fuel sources:

Coal fines will be sourced from up to three mines in the Delmas and Middelburg areas. Approximately

2600m³ of coal fines will be stored onsite at any one time in a dome located within the coal fines feedstock

holding area. The consumption of coal fines are expected to be 420 480 tonnes per year. Natural gas will

be supplied via the existing Sasol pipeline situated along Spanner Road and Syngas will be sourced from

the Bellmall Energy Syngas Plant situated at remote locations and will be transported to site via trucks.




Ash Disposal:

Ash generated by the combustion process will be removed from the boilers (i.e. bottom ash) and flue

gases (i.e. fly ash) and will be transported via trucks back to the mines from where coal fines are to be

sourced. Here it will be utilised as part of rehabilitation and mine backfilling. The ash can also be used in

the manufacture of concrete, cement clinker, aggregate substitute cement blocks and larger granules of

bottom ash can be used for construction of roads.

Storage and Handling of Hazardous substances:

During the operation phase, the handling and storage of materials will include diesel, water treatment

additives and chemicals. The combined capacity of storage containers will not exceed 80m³.

Limestone:

Limestone will be transported to site via road transport from Pretoria and Vereeniging, and will be

transferred and stored within a silo adjacent to the central plant. The limestone will be transferred via

conveyors to the limestone bunkers in the boiler-house, as required. The limestone consumption is

expected to be 43 800 tonnes per year.

Employment:

The proposed facility will create between 14 and 25 permanent employment positions during operation.

The permanent employment positions will include highly skilled, skilled and semi-skilled positions.

Water requirements:

Approximately 50-70kl of water per day will be required during the operation phase. The water will be

obtained from Astral Foods’ effluent wastewater, as well as through return water from the various off-takers

within the industrial area. Approximately 6000kl per day of wastewater will be stored in holding tanks

onsite. Water will be treated to the required standard for use in the steam generation plant within a waste

water treatment works which will be developed on the site of the Clayville Thermal Plant. Should the

wastewater from Astral not be sufficient at any given time during operation, municipal water will be

utilised. In addition, the applicant will harvest rainfall on the site as much as possible, and treat it via the

wastewater treatment plant before utilising the water within the steam producing process. The

development will utilise heat from the CFB boiler to heat any hot water requirements on-site. Prior to the

operation of the CFB boiler, solar water heating and heat pumps will be utilised.

3.5.3 Decommissioning Phase

The lifespan of the Clayville Thermal Plant will be more than 35 years. Equipment associated with this

facility would only be decommissioned once it has reached the end of its economic life or if it is no longer

required.

Decommissioning activities will involve disassembly of the steam generation units and ancillary

infrastructure, demolishing of buildings and rehabilitation of the site to the desired end-use. As far as

possible, components will be broken down and recycled.



Approach to Undertaking the EIA Phase Page 44

CHAPTER 4: APPROACH TO UNDERTAKING THE EIA PHASE

In terms of the EIA Regulations of December 2014 (published in terms of the National Environmental

Management Act (NEMA; No. 107 1998), as amended, the construction and operation of the proposed

Clayville Thermal Plant is a listed activity requiring environmental authorisation. This EIA process for the

proposed Clayville Thermal Plant is being undertaken in accordance with the Section 24 (5) of the National

Environmental Management Act (No 107 of 1998). This EIA process aims at assessing the impacts

associated with the proposed project and identifying appropriate mitigation measures for the minimisation

of the impacts. This was achieved through an assessment of the proposed project involving ground-

truthed specialist inputs, as well as a consultation process with the Interested and Affected Parties (I&APs),

the decision making authorities, directly impacted landowners/occupiers, adjacent

landowners/occupiers, relevant organs of state departments, the ward councillor and other key

stakeholders. This chapter serves to outline the process which was followed during the EIA Phase of the EIA

process.

The EIA process culminates in the submission of an EIA Report (including an Environmental Management

Programme (EMPr) to the competent authority for decision-making. The EIA process is illustrated below:

Figure 4.1: The Phases of an EIA Process



This chapter of the final EIA Report includes the following information required in terms of Appendix 3:

Content of Environmental Impact Assessment Reports:


3(d)(i) a description of the scope of the proposed

activity, including all listed activities triggered and being

applied for.

The listed activities triggered due to the development of

the Clayville Thermal Plant is included in Section 4.2,

Table 4.1 and Table 4.2.

3(h)(ii) details of the public participation process

undertaken in terms of regulation 41 of the Regulations,

including copies of the supporting documents and

inputs.

The details of the public participation process

undertaken for the Clayville Thermal Plant is included in

Sections 4.3 and 4.4. Evidence of the Public Participation

Process is included in Appendix C.

3(h)(iii) a summary of the issues raised by interested and A summary of the issues raised to date are included in





affected parties, and an indication of the manner in

which the issues were incorporated, or the reasons for not

including them.

Section 4.4.4. A summary of issued raised during the EIA

Report 30-day review period are included in this final EIA

Report as Appendix C – Comments and Responses

Report.

3(h)(vi) the methodology used in determining and

ranking the nature, significance, consequences, extent,

duration and probability of potential environmental

impacts and risks.

The methodology for the assessment of the impacts has

been included in Section 4.4.5.

3(p) a description of any assumptions, uncertainties, and

gaps in knowledge which relate to the assessment and

mitigation measures proposed.

A descriptions of the assumptions and limitation

associated with the assessment of the Clayville Thermal

Plant is included in Section 4.4.6.

4.2. Relevant legislative permitting requirements

The legislative permitting requirements applicable to the Clayville Thermal Plant and associated

infrastructure identified at this stage in the process are identified below.

4.2.1. National Environmental Management Act (No. 107 of 1998) (NEMA)

Listed Activities are activities identified in terms of Section 24 of NEMA which are likely to have a

detrimental effect on the environment, and which may not commence without Environmental

Authorisation (EA) from the competent authority. EA required for Listed Activities is subject to the

completion of an environmental assessment process (either a Basic Assessment (BA) or full Scoping and

Environmental Impact Assessment (S&EIA)).

Error! Reference source not found. contains the Activities identified in terms of the EIA Regulations (i.e. GN

R324, GN R325 and GN R327) which may be triggered by the project, and for which an EA has been

applied through means of an application for EA. The table also includes a description of those project

activities which relate to the applicable Listed Activities.

Table 4.1: Listed activities triggered by the Clayville Thermal Plant

Indicate the number

and date of the

relevant notice:

Activity No (s) (in terms

of the relevant notice) :

Describe each listed activity as per project description

GN 327, 08 December

2014 (as amended on

07 April 2017)

25 The development and related operation of facilities or

infrastructure for the treatment of effluent, wastewater or sewage

with a daily throughout capacity of more than 2 000 cubic metres

but less than15 000 cubic metres.

A water treatment plant associated with the thermal plant will

treat up to 6 000 cubic metres of effluent wastewater per day.

GN 325, 08 December

2014 (as amended on

07 April 2017)

6 The development of facilities or infrastructure for any process or

activity which requires a permit or licence or an amended permit

or licence in terms of the national or provincial legislation

governing the generation or release of emissions, pollution or

effluent.

An Air Emissions Licence is required to be obtained for the




Indicate the number

and date of the

relevant notice:

Activity No (s) (in terms

of the relevant notice) :

Describe each listed activity as per project description

development of the Clayville Thermal Plant in terms of the NEM:

Air Quality Act.

4.2.2. National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA)

The List of Activities which Result in Atmospheric Emissions (GNR 893) are activities identified in terms of

Section 21 of the National Environmental Management: Air Quality Act (No. 39 of 2004) (NEM:AQA) which

result in atmospheric emissions and which have or may have a significant detrimental effect on the

environment, including health, social conditions, economic conditions, ecological conditions or cultural

heritage; and which may not commence without an Atmospheric Emission License (AEL).

An applicant wishing to undertake an activity identified in terms of the List of Activities which result in

Atmospheric Emissions (GNR 893) must apply for an Atmospheric Emissions License (AEL) by lodging an

online application with the Atmospheric Emissions Licensing Authority (AELA), in this instance the Ekurhuleni

Metropolitan Municipality). The process of applying for an AEL is required to be supported by an

Atmospheric Impact Report, and will only be completed once the EIA process has been finalised and

Environmental Authorisation (EA) has been obtained for the project.

Table 4.2 contains activities identified in terms of NEM:AQA and the List of Activities which Result in

Atmospheric Emissions (GNR 893) of 22 November 2013 which may be triggered by the proposed project,

and for which an AEL is required. The table also includes a description of those project activities which

relate to the applicable Atmospheric Emission Activities.

Table 4.2: Activities identified in terms of the List of Activities which result in Atmospheric Emissions (GNR

893) published under NEM:AQA on 22 November 2013.

Notice No. Activity No : Description of Atmospheric Emission Activity:

GNR 893

22

November

2013

Category 1

Combustion

Installations

Subcategory 1.1:

Solid Fuel

Combustion

Installations

Description: Solid fuels combustion installations used primarily for steam

raising or electricity generation.

Application:

All installations with design capacity equal to or greater than

50MW heat input per unit, based on the lower calorific value

of the fuel used.

Substance or mixture of

substances Plant

Status

mg/Nm³ under normal

conditions of 10% O2, 273

Kelvin and 101.3 kPa. Common

Name

Chemical

Symbol

Particulate

Matter N/A

New 50

Existing 100

Sulphur

dioxide SO2

New 500

Existing 3500

Oxides of

nitrogen

NOX expressed

as NO2

New 750

Existing 1100

The operation of the proposed project will burn coal fines, a solid fuel in a

combustion process to generate steam.

GNR 893 Category 1 Description: Gas combustion (including gas turbines burning natural gas)




Notice No. Activity No : Description of Atmospheric Emission Activity:

22

November

2013

Combustion

Installations

Subcategory 1.4:

Gas Combustion

Installations

used primarily for steam raising or electricity generation.

Application:

All installations with design capacity equal to or greater than

50MW heat input per unit, based on the lower calorific value

of the fuel used.

Substance or mixture of

substances Plant

Status

mg/Nm³ under normal

conditions of 10% O2, 273

Kelvin and 101.3 kPa. Common

Name

Chemical

Symbol

Particulate

Matter N/A

New 10

Existing 10

Sulphur

dioxide SO2

New 400

Existing 500

Oxides of

nitrogen

NOX expressed

as NO2

New 50

Existing 300

The operation of the proposed project will use gas as a feedstock in a

combustion process to generate steam.

4.2.3. EIA Regulations, 2014 as amended (GNR326)

On the basis of the above listed activities, a Scoping and EIA Process has been undertaken for the Clayville

Thermal Plant. This process comprised two phases as follows:

» The Scoping Phase included the identification of potential issues associated with the project through a

desktop study and consultation with interested and affected parties and key stakeholders. Areas of

sensitivity within the project site were identified and delineated in order to identify any environmental

fatal flaws, and sensitive or no go areas. Following a 30-day review period of the draft report, this

phase culminated in the submission of a final Scoping Report and Plan of Study for EIA to the GDARD.

Acceptance of the Scoping Report was received in December 2017.

» The EIA Phase involves a detailed assessment and ground-thruthing of potentially significant positive

and negative impacts (direct, indirect, and cumulative) identified in the Scoping Phase. This phase

includes detailed specialist investigations and public consultation. Following the review period of the

draft report, this phase culminates in the submission of a final EIA Report and an Environmental

Management Programme (EMPr), including recommendations of practical and achievable mitigation

and management measures, to the GDARD for review and decision-making.

4.3. Scoping Phase

A Scoping Study was undertaken in accordance with the requirements of the EIA Regulations. The

Scoping Study provided I&APs with the opportunity to receive information regarding the project,

participate in the process, and submit comments on the Scoping Report. The Scoping Report detailed the

nature and extent of the project, identifying potential issues associated with the Thermal Plant, and

defined the extent of studies required within the EIA Phase. This was achieved through an evaluation of

the project, involving the project proponent, review of existing information, and a consultation process

with key stakeholders that included both relevant government authorities and I&APs.




A Scoping Report was released for review from 26 September 2017 – 26 October 2017 for a 30-day

comment period. Following the review period, a final Scoping Report was submitted to GDARD in

November 2017. This together with the Plan of Study for the EIA was accepted by the GDARD, as the

competent authority, in December 2017. In terms of this acceptance, an EIA is required to be undertaken

for the Clayville Thermal Plant.

Following this, the applicant consulted with the National Energy Regulator of South Africa (NERSA) in order

to confirm compliance of the proposed project with relevant legislation and to confirm the feedstock type

and source. Confirmation in this regard was received in March 2018. The EIA project schedule was

therefore delayed, and the applicant and specialist consulting team were not in a position to provide the

Competent Authority with all the information requested within the prescribed timeframes. Subsequently,

the applicant requested that the file be closed on 18 May 2018. In terms of Regulation 21(2) of the EIA

Regulations of 2014 (as amended), the findings of the scoping report remain valid and the environmental

context has not changed. Therefore, the EIA process is proceeding from the EIA Phase following the

submission of a new application form.

4.4. EIA Phase

The EIA Phase aims to achieve the following:

» Provide a comprehensive assessment of the social and biophysical environments affected by the

Clayville Thermal Plant.

» Assess potentially significant impacts (direct, indirect, and cumulative, where required) associated with

the project.

» Comparatively assess any feasible alternatives put forward as part of the project.

» Identify and recommend appropriate mitigation measures for potentially significant environmental

impacts which cannot be avoided.

» Undertake a fully inclusive public participation process to ensure that I&APs are afforded the

opportunity to participate, and that their comments are recorded.

This final EIA Report assesses potential direct, indirect, and cumulative impacts (both positive and

negative) associated with all phases of the project including design, construction, operation and

decommissioning. In this regard this final EIA Report aims to provide the relevant authorities with sufficient

information to make an informed decision regarding the Clayville Thermal Plant.

4.4.1. Tasks completed during the EIA Phase

The EIA Phase for the Clayville Thermal Plant has been undertaken in accordance with the EIA Regulations,

2014, as amended in April 2017, in terms of NEMA. Key tasks undertaken within the EIA phase included:

» Consultation with relevant decision-making and regulating authorities (at National, Provincial and

Local levels).

» Undertaking of independent specialist studies in accordance with Appendix 6 of Government Notice

R326 of the EIA Regulations, 2014, as amended.

» Preparation of an EIA Report in accordance with Appendix 3 of Government Notice R326 of the EIA

Regulations, 2014, as amended.




» Undertaking a public participation process throughout the EIA process in accordance with Chapter 6

of Government Notice R326 of the EIA Regulations, 2014 (as amended) in order to record comments

associated with the Clayville Thermal Plant.

» Preparation of a Comments and Response Report including all comments received from I&APs and

Organs of State as part of the EIA Process.

These tasks are discussed in detail below.

4.4.2. Authority Consultation

As the project is located in the Gauteng Province, the competent authority responsible for the decision

making regarding the authorisation of the project is the provincial department, the Gauteng Department

of Agriculture and Rural Development (GDARD). Consultation with the relevant authority has been

undertaken throughout the Scoping process. Authority consultation has included the following:

» Pre-application consultation meeting held on 29 August 2017.

» Submission of the application for authorisation to GDARD;

» Submission of the Scoping Report for review by the competent and commenting authority from 26

September 2017 – 26 October 2017.

» Submission of the final Scoping Report for the Clayville Thermal Plant submitted in November 2017 to

GDARD and accepted in December 2017.

» Consultation with GDARD throughout the EIA process.

» Consultation with the AEL Authority, the City of Ekurhuleni Metropolitan Municipality, on 17 November

2017.

» Consultation with the AEL Authority, the City of Ekurhuleni Metropolitan Municipality, on 12 February

2018.

» Submission of new application to GDARD following lapsing of previous process.

» The EIA Report were made available to the GDARD for a 30-day review period from 26 June 2018 to 26

July 2018.

The following have also been undertaken as part of this EIA Phase:

» Notification and consultation with Organs of State (refer to Table 4.3) that may have jurisdiction over

the project, including:

Provincial Departments;

Parastatals and Non-Governmental Organisations;

The City Ekurhuleni Metropolitan Municipality.

» Submission of a final EIA Report to GDARD following the 30-day public review period of the EIA Report

and the receipt of the comments from the GDARD on the Report. This final EIA Report include all

comments and issues raised by I&APs and the responses of the EAP and the project development

team.

» If required, an opportunity for GDARD representatives to visit and inspect the proposed project site.

A record of all authority consultation in the EIA and AEL processes is included within Appendix C.




4.4.3. Public Participation Process

The aim of the public participation process is primarily to ensure that:

» Information containing all relevant facts in respect of the project is made available to potential

stakeholders and I&APs.

» Participation by potential I&APs is facilitated in such a manner that all potential stakeholders and I&APs

are provided with a reasonable opportunity to comment on the project.

» Comments received from stakeholders and I&APs are recorded and incorporated into the EIA process.

In order to accommodate the varying needs of stakeholders and I&APs within the study area, as well as

capture their comments regarding the development of the Clayville Thermal Plant, various opportunities

for stakeholders and I&APs to be involved in the EIA Phase of the process have been provided, as follows:

» Opportunity for review of the EIA Report for a 30-day period from 26 June 2018 – 26 July 2018.

Comments received from I&APs during this period have been captured within a Comments and

Response Report, which are included within this Final EIA Report, for submission to the GDARD for

decision-making.

» Focus Group Meetings: Focus group meetings were held with the City of Ekurhuleni, and key

representatives including the Greater Midstream Forum and Olifantsfontein Business Forum in July 2018.

The purpose of these focus group meetings was to present the findings of the EIA Report, to facilitate

and record comments on the EIA Report. The minutes of these meetings are included in this final EIA

Report submitted to the GDARD.

» Telephonic Consultation Sessions: Telephonic consultation will be held with I&APs, including Organs of

State Departments and key stakeholders to capture issues, comments and concerns regarding the

project and to follow-up on the submission of comments on the EIA Report.

» Written, faxed or e-mail correspondence.

In compliance with the requirements of Chapter 6 of the EIA Regulations, 2014, the following summarises

the key public participation activities conducted to date (also see Table 4.4).

(i) Placement of Site Notices

Placement of site notices announcing the EIA process at visible points along the boundary of the project

site on 05 September 2017, in accordance with the requirements of the EIA Regulations. Photographs and

the GPS coordinates of the site notices are contained in Appendix C2.

(ii) Identification of I&APs and establishment of a database

Identification of I&APs was undertaken by Savannah Environmental through existing contacts and

databases, recording responses to site notices and newspaper advertisements, as well as through the

process of networking from the commencement of the EIA process. The key stakeholder groups identified

include authorities, the metropolitan municipality, organs of state departments, state-owned companies

and non-governmental organisations (refer to Table 4.3 below).




Table 4.3: Summary of Stakeholders identified for inclusion in the project database during the Public

Participation Process of the Clayville Thermal Plant EIA Process

Organs of State

National Government Departments

Department of Agriculture, Forestry and Fisheries (DAFF)

Department of Rural Development and Land Reform (DRDLR)

Department of Water and Sanitation (DWS)

Government Bodies and State Owned Companies

Sentech

South African Civil Aviation Authority (CAA)

South African Heritage Resources Agency (SAHRA)

South African National Roads Agency Limited (SANRAL)

Telkom SA Ltd

Transnet

Provincial Government Departments

Gauteng Department of Agriculture and Rural Development (GDARD)

- Sustainable Use of Environment Directorate

- Climate Change and Information Management Directorate

- Agriculture Department

Gauteng Department of Roads and Transport

Provincial Heritage Resources Authority Gauteng (PHRAG)

Local Government Departments

Ekurhuleni Metropolitan Municipality

Landowners

Olifantsfontein Business Forum

Affected landowners and tenants

Neighbouring landowners and tenants

As per Regulation 42 of the EIA Regulations of 2014 (as amended) all relevant stakeholder and I&AP

information has been recorded within a register of I&APs (refer to Appendix C for a listing of recorded

parties). While I&APs were encouraged to register their interest in the EIA process from the onset, the

identification and registration of I&APs has been on-going for the duration of the EIA process.

(iii) Advertisements and Notifications

» Placement of advertisements announcing the EIA process for the project and inviting members of the

public to register themselves as I&APs on the project database and announcing the availability of and

inviting comment on the Scoping Report were placed in the Midrand Reporter on 22 September 2017,

at the commencement of the 30-day review period (refer to Appendix C2).

» Compilation of a background information document (BID) for the project in order to provide

information regarding the Clayville Thermal Plant project and the EIA process (refer to Appendix C3).

The BID has been distributed to identified stakeholders and I&APs.

» Distribution of an EIA process notification letter regarding the Clayville Thermal Plant project and of the

availability of the Scoping Report for review, together with stakeholder reply forms. This letter was

distributed to organs of state, potentially affected and neighbouring landowners as well as registered

stakeholders/I&APs via email and registered post on 26 September 2017. I&APs have been




encouraged to view the Scoping Report and submit written comment thereon. Proof of distribution is

contained in Appendix C5.

» Distribution of CD and hard copy versions of the Scoping Report to Organs of State via courier at the

commencement of the review period. The evidence of distribution of the Scoping Report have been

included in Appendix C.

» A letter notifying I&APs of the lapsing of the file which was distributed on 20 May 2018 via email. The

evidence of this distribution is included in Appendix C4 and Appendix C5.

» An advertisement announcing the re-commencement of the EIA process (including new EIA

Reference Number) and the availability of the EIA Report and inviting comment was placed in the

Midrand Reporter on 28 June 2018. The tear sheet of the newspaper advert is included in Appendix C2

of this final EIA Report, once received from the newspaper.

» Letters notifying registered I&APs of the re-commencement of the EIA process (including new EIA

Reference Number) and the availability of the Clayville Thermal Plant EIA Report for review were

distributed to registered I&APs via email on 26 June 2018 and registered post on the onset of the review

period.

» Copies of the EIA Report were couriered to Organs of State Departments at the onset of the review

period.

» A hard copy of the EIA Report was placed at the Olifantsfontein Library (c/o Pearce & Mason Avenue,

Olifantsfontein, Kempton Park) and at the Winnie Mandela Library (Margaret Zyma Street, Tembisa) for

members of the public to view. The evidence of the distribution of the EIA Report is contained in

Appendices C4 and C5.

(iv) Public Involvement and Consultation

In order to accommodate the varying needs of stakeholders and I&APs, the following opportunities have

been provided for I&AP issues to be recorded and considered through the EIA process as outlined in Table

4.4 below:

Table 4.4: Consultation undertaken with I&APs in the Clayville Thermal Plant EIA Process

Scoping

Phase

Activity Date

Presentation to the Olifantsfontein Business Forum 03 August 2017

The EIA process was advertised in the Midrand Reporter newspaper. 22 September 2017

Placement of site notices, on-site and in public places. 05 September 2017

Distribution of process notification letters (including notification of the

availability of the Scoping Report) and background information

documents to organs of state departments, ward councillors,

landowners within the study area, neighbouring landowners and

stakeholder groups.

26 September 2017

Distribution of the Scoping Report and notification letters inviting

comment on the report via courier to organ of state departments.

26 September 2017

Review period for the Scoping Report for public comment. 26 September 2017 – 26

October 2017

Focus Group Meetings:

» Key stakeholders focus group meeting

» Ward Councillor of Ward 1 of the Ekurhuleni Metropolitan

Municipality

17 October 2017

EIA Phase Distribution of letters announcing the re-commencement of the EIA

process (including new EIA Reference Number) and the availability of

26 June 2018




the EIA Report for review for a 30-day comment period and the dates

and venues of the Public Meetings. These letters have been distributed

to organs of state departments, ward councillors, landowners within the

study area, neighbouring landowners and key stakeholder groups.

The re-commencement of the EIA process (including new EIA

Reference Number) and the availability of the EIA Report has been

advertised in the Midrand Reporter newspaper.

28 June 2018

30-day review period of the EIA Report for public comment. 26 June 2018 – 26 July

2018

Public Participation meetings to be held during the 30-day comment

period:

Focus Group Meetings:

» City of Ekurhuleni;

» Greater Midstream Forum;

» Olifantsfontein Business Forum

26 June 2018 – 26 July

2018

Records of all consultation undertaken are included in Appendix C.

4.4.4. Identification and Recording of Issues and Concerns

Issues and comments raised by I&APs over the duration of the EIA process have been synthesised into a

Comments and Responses Report and summarised in Table 4.5 below. The Comments and Responses

Report includes detailed responses from members of the EIA project team and the applicant. This is

included in Appendix C.

Table 4.5: Summary of issues raised through the Public Participation Process

Issue Raised By: Summary of main issues raised by

I&APs

Summary of response from EAP

Paul Claassen

Greater

Midstream

Forum

Any project or any project extension

needs to be considered within the

context of the relevant policy and the

successful implementation thereof by

the authorities.

The assessment of the proposed project will consider

relevant policy and legislation. An Air Emissions

License (AEL) will be required for the project,

application for which will be submitted to the

Ekurhuleni Metropolitan Municipality after the EIA

process has been concluded.

Paul Claassen

Greater

Midstream

Will a Water Use License be required for

this project?

According to the activities being triggered, a Water

Use License is not required for this project as the

amount of water to be stored on site is below the

threshold.

Paul Claassen

Greater

Midstream

Forum

There are many problems relating to

sinkholes in this area.

The EMPr submitted as part of the final EIA Report

recommends that a Geotechnical Assessment be

undertaken before the project commences (Section

4, Objective 1). According to the comments received

from the City of Ekurhuleni Municipality dated 27 July

2018, the project site has geotechnical development

constraints with a low sensitivity rating.

Paul Claassen

Greater

Midstream

Forum

Mercury is a constituent of coal, but in

trace amounts. It was not considered

in the Air Quality Impact Assessment

because a relatively small amount of

It is noted that mercury has in earlier years been a

significant concern in the area and communities.

Although Mercury is a component of coal, it is in trace

amounts. It was not considered in the Air Quality





I&APs


coal will be used initially, and then the

plant will be operated using Syngas or

natural gas.

Impact Assessment as a relatively small amount of

coal will be used. If mercury is to be assessed, there is

no regulatory emission requirements for mercury to

measure the results against and therefore no

conclusion could be drawn regarding the

acceptability of any impact. Without a standard to

measure Mercury against, there is no way to assess

compliance. The ambient mercury concentration is

unknown, which makes it very difficult to assess

impacts.

Paul Claassen

Greater

Midstream

Forum

No positive impacts in terms of

reduction of individual boilers can be

assumed in the EIA Report without

stipulating at the very least what boilers

and to what extent air pollution will be

reduced.

The positive impacts associated with the

decommissioning of other current air polluting

activities were not included as no commitment from

emitters have been obtained at this stage in the

process. The Air Quality Impact Assessment has

however assessed the “worst case scenario” where no

polluting activities will be decommissioned, and the

risk associated with the proposed development from

an air quality and human health risk perspective is

considered to be of low significance and acceptable.

Should some polluting activities be decommissioned

due to the operation of the Clayville Thermal Plant,

there will be a reduction of different emission sources

from the various boilers within the area and emissions

will be concentrated to one source. The commitment

from the individual off-takers to decommission their

small boilers on-site will form part of the contractual

agreement.

Paul Claassen

Greater

Midstream

Forum

The time period for the use of coal fines

as the initial fuel is not specified or

committed to.

Coal fines will be used to initiate the project. The

applicant cannot commit to timelines for the use of

syngas or natural gas due to current market prices

which are considered to be economically unfeasible.

The central plant can use gas in the project's next

stage if Sasol’s gas price reduces or an alternative

affordable gas source becomes available. The

recommendation in the EIA (section 8.7) is that the

plant be designed to ultimately cater for the use of

syngas and natural gas as a fuel source.

Barend Deminey

Divisional Head:

Functional

Planning

Roads and

Stormwater

Department

City of Ekurhuleni

Municipality

The department requires that provision

should be made for a deceleration

lane on the north-bound approach

along Industry Road into the proposed

development, given that the proposed

ingress throat length only caters for one

interlink.

The applicant takes note of the Department’s

requirement to make provision for a deceleration

lane. The traffic specialist has recommended that a

deceleration lane should be constructed on Industry

Road to accommodate left-turn vehicles entering the

development, or introduce a second entry lane at the

site access on Industry Road (refer to Traffic Impact

Assessment (refer to Appendix F) and EMPr).

Alternatively, additional access to the site can be

obtained via Spanner Road, to improve on-site

manoeuvrability, to reduce right-turn exit movements

at the development access and to reduce traffic





I&APs


impact on Industry Road.

JA Zeederberg

Chairperson

& Mr P Claassen

Great Midstream

Forum

The proposed activity may contribute

to deteriorating ambient air quality

(cumulative impact) in the area. It

may also release gaseous emissions or

vapours (even at low concentrations).

As detailed in the Scoping Report, impacts on air

quality during the construction phase will relate to

dust pollution. The significance of this impact is

expected to be low as low-level sources generally

impact close to the source. The impact can be

mitigated through optimisation of dust control

measures which will be included in the Environmental

Management Programme during the EIA phase.

Emissions of gaseous pollutants and particulates from

the stack as a result of operational activities has been

considered. The significance of the potential impact

is expected to be low as elevated stack emissions

generally disperse effectively resulting in low ground-

level concentrations. The impact can be mitigated

through optimisation of emission abatement. The

significance of the impacts will be confirmed during

the EIA Phase when air dispersion modelling will be

undertaken to predict ambient concentrations of air

pollutants.

JA Zeederberg

Chairperson

& Mr P Claassen

Great Midstream

Forum

The Regional Spatial Development

Framework of the Ekurhuleni

Metropolitan Municipality, 2015,

earmarked the areas directly to the

north and west of the

Olifantsfontein/Clayville industrial areas

as Urban Development zones that

excludes industrial development as a

land use. The general area is further

earmarked for infill and urban

densification with several high density

social housing projects in the

immediate vicinity of the

Olifantsfontein/ Clayville industrial area.

The industrial growth direction

indicated in the RSDF is towards the

south-south-east in the general

direction of the OR Tambo International

Airport and in line with the Aerotropolis

initiative of the Ekurhuleni Metropolitan

Municipality.

As per the Regional Spatial Development Framework

of the Ekurhuleni Metropolitan Municipality, 2015, the

Clayville Industrial Area falls within Region B. Although

it is the vision of the municipality that this area will be

subject to major urban growth due to the proximity to

the airport and its expected growth as an

aerotropolis, the Framework recognises the

Olifantsfontein area as a focus area for industrial

development. Furthermore, the Gauteng Provincial

Environmental Management Framework of 2014

provides a strategic and overall framework for

environmental management in Gauteng while

aligning sustainable development initiatives with the

environmental resources, developmental pressures, as

well as the growth imperatives of Gauteng. The

GPEMF has divided the Gauteng Province into five

Environmental Management Zones (EMZs). The

purpose of these zones is to identify specific planning

and policy measures associated with a specific zone

to achieve the development objectives of the zone.

The Clayville Thermal Plant falls within Zone 5 which is

the industrial and commercial development focus

zone indicating that the area is earmarked for the

development of industrial industries. It can therefore

be expected that various industrial developments will

take place in addition to the already industrial nature

of the area.




4.4.5. Assessment of Issues Identified through the Scoping Process

As detailed in the accepted Plan of Study for EIA, the following issues were identified through the Scoping

Study as not requiring further investigation within the EIA, and no further or detailed assessment is required:

» Impacts on palaeontology – due to the lack of fossil heritage within the project site and the low

significance of the impact on the palaeontological resources, no further Palaeontological Impact

Assessment is required for the EIA Phase.

» Impacts on the social environment – the majority of impacts are expected to be localised and

restricted to the site. Positive impacts associated with employment creation and skills development will

be managed through appropriate recruitment mechanisms. Only potential impacts associated with

increased traffic are required to be further investigated within the EIA Phase of the process.

Issues which require investigation within the EIA Phase as identified through the Scoping Study, as well as

the specialists involved in the assessment of these impacts are indicated in Table 4.6 below.

Table 4.6: Specialist studies required for the Clayville Thermal Plant project

Specialist Study Specialist Refer Appendix

Air Quality Mark Zunckel of uMoya-NILU Appendix D

Heritage Jaco van der Walt of Heritage Contracts and

Archaeological Assessments (HCAC)

Appendix E

Traffic Stephen Fautley of Techso Appendix F

Specialist studies considered direct and indirect environmental impacts associated with the development

of all components of the Clayville Thermal Plant. Issues were assessed in terms of the following criteria:

» The nature, a description of what causes the effect, what will be affected, and how it will be affected.

» The extent, wherein it is indicated whether the impact will be local (limited to the immediate area or

site of development), regional, national or international. A score of between 1 and 5 is assigned as

appropriate (with a score of 1 being low and a score of 5 being high).

» The duration, wherein it is indicated whether:

The lifetime of the impact will be of a very short duration (0–1 years) – assigned a score of 1;

The lifetime of the impact will be of a short duration (2-5 years) - assigned a score of 2;

Medium-term (5–15 years) – assigned a score of 3;

Long term (> 15 years) - assigned a score of 4;

Permanent - assigned a score of 5.

» The magnitude, quantified on a scale from 0-10, where a score is assigned:

0 is small and will have no effect on the environment;

2 is minor and will not result in an impact on processes;

4 is low and will cause a slight impact on processes;

6 is moderate and will result in processes continuing but in a modified way;

8 is high (processes are altered to the extent that they temporarily cease);

10 is very high and results in complete destruction of patterns and permanent cessation of

processes.

» The probability of occurrence, which describes the likelihood of the impact actually occurring.

Probability is estimated on a scale, and a score assigned:




Assigned a score of 1–5, where 1 is very improbable (probably will not happen);

Assigned a score of 2 is improbable (some possibility, but low likelihood);

Assigned a score of 3 is probable (distinct possibility);

Assigned a score of 4 is highly probable (most likely);

Assigned a score of 5 is definite (impact will occur regardless of any prevention measures).

» The significance, which is determined through a synthesis of the characteristics described above (refer

formula below) and can be assessed as low, medium or high.

» The status, which is described as either positive, negative or neutral.

» The degree to which the impact can be reversed.

» The degree to which the impact may cause irreplaceable loss of resources.

» The degree to which the impact can be mitigated.

The significance is determined by combining the criteria in the following formula:

S = (E+D+M) P; where

S = Significance weighting

E = Extent

D = Duration

M = Magnitude

P = Probability

The significance weightings for each potential impact are as follows:

» < 30 points: Low (i.e. where this impact would not have a direct influence on the decision to develop in

the area);

» 30-60 points: Medium (i.e. where the impact could influence the decision to develop in the area unless

it is effectively mitigated);

» > 60 points: High (i.e. where the impact must have an influence on the decision process to develop in

the area).

As per the requirements of the EIA Regulations, specialist studies are required to assess the cumulative

impacts. The role of the cumulative assessment is to test if such impacts are relevant to the project in the

proposed location (i.e. whether the addition of the project in the area will increase the impact). This

section should address whether the construction of the Clayville Thermal Plant together with all the projects

proposed or existing in the area will result in:

» Unacceptable risk;

» Unacceptable loss;

» Complete or whole-scale changes to the environment or sense of place; and

» Unacceptable increase in impact.

As the developer has the responsibility to avoid or minimise impacts and plan for their management (in

terms of the EIA Regulations), the mitigation of significant impacts are required to be recommended.

Assessment of impacts with mitigation is made in order to demonstrate the effectiveness of the proposed

mitigation measures. An Environmental Management Programme (EMPr) is included as Appendix H.




4.4.6. Assumptions and Limitations

The following assumptions and limitations are applicable to the studies undertaken within this EIA Phase:

» All information provided by the developer and I&APs to the environmental team was correct and valid

at the time it was provided.

» It is assumed that the development site identified by the developer represents a technically suitable

site for the establishment of Clayville Thermal Plant.

» Studies assume that any potential impacts on the environment associated with the Clayville Thermal

Plant will be avoided, mitigated, or offset.

» This report and its investigations are project-specific, and consequently the environmental team did

not evaluate any other technology alternatives.

Refer to the specialist studies in Appendices D – F for specialist study specific limitations.

4.5. Legislation and Guidelines that have informed the preparation of this Environmental Impact

Assessment Report

The following legislation and guidelines have informed the scope and content of this final EIA report:

» National Environmental Management Act (Act No. 107 of 1998);

» EIA Regulations of December 2014, published under Chapter 5 of NEMA (as amended in GNR R326 in

Government Gazette No 40772 of April 2017);

» International guidelines – the Equator Principles and the International Finance Corporation and World

Bank Guidelines.

Several other Acts, standards or guidelines have also informed the project process and the scope of issues

evaluated in this EIA report. A listing of relevant environmental legislation, as well as the compliance

requirements applicable to the Clayville Thermal Plant in terms of this legislation is provided in Table 4.7.




Table 4.7: Review of the relevant environmental policies, legislation, guidelines and standards applicable to the Clayville Thermal Plant

Legislation Applicable Sections Relevant Authority Compliance Requirements

National Legislation

Constitution of the Republic of

South Africa (Act No 108 of 1996)

» Bill of Rights (S2)

» Environmental Rights (S24) – i.e. the right to an

environment which is not harmful to health and well-

being

» Rights to freedom of movement and residence (S22)

» Property rights (S25)

» Access to information (S32)

» Right to just administrative action (S33)

» Recognition of international agreements (S231)

Applicable to all

authorities

There are no permitting requirements associated

with this Act.

The application of the Environmental Right

however implies that environmental impacts

associated with proposed developments are

considered separately and cumulatively. It is

also important to note that the “right to an

environment clause” includes the notion that

justifiable economic and social development

should be promoted, through the use of natural

resources and ecologically sustainable

development.

National Environmental

Management Act (Act No 107 of

1998)

» National environmental principles (S2), providing

strategic environmental management goals and

objectives of the government applicable throughout

the Republic to the actions of all organs of state that

may significantly affect the environment

» NEMA EIA Regulations (GN 324 – 327 of December

2014, as amended in April 2017)

» The requirement for potential impact on the

environment of listed activities must be considered,

investigated, assessed and reported on to the

competent authority (S24 – Environmental

Authorisations)

» Duty of Care (S28) requiring that reasonable measures

are taken to prevent pollution or degradation from

occurring, continuing or recurring, or, where this is not

possible, to minimise & rectify pollution or degradation

of the environment

Gauteng Department

of Agriculture and

Rural Development

(GDARD)

In terms of the EIA Regulations, 2014 (as

amended) - GN R325, GN R326 and GN R327 - a

scoping and EIA process is required to be

undertaken for the development of the Clayville

Thermal Plant. The Scoping report was

accepted by GDARD in December 2017. This EIA

Report will be submitted to the competent

authority in support of the application for

authorisation.





» Procedures to be followed in the event of an

emergency incident which may impact on the

environment (S30)

» Appeals against decisions made by authorities (S43)


Management Act (Act No 107 of

1998)

» In terms of the Duty of Care provision in S28(1) the

project proponent must ensure that reasonable

measures are taken throughout the life cycle of this

project to ensure that any pollution or degradation of

the environment associated with this project is

avoided, stopped or minimised.

» In terms of NEMA, it has become the legal duty of a

project proponent to consider a project holistically,

and to consider the cumulative effect of a variety of

impacts.

National Department

of Environmental Affairs

(as the regulator of

NEMA).

While no permitting or licensing requirements

arise directly, this section finds application during

the EIA phase and will continue to apply

throughout the life cycle of the project.

Environment Conservation Act

(Act No 73 of 1989)

» National Noise Control Regulations (GN R154 dated 10

January 1992)

Ekurhuleni Metropolitan

Municipality

Noise impacts are expected to be associated

with the construction and operation phases of

the project and are not likely to present a

significant intrusion to the local community.

There is therefore no requirement for a noise

permit in terms of the legislation.

National Heritage Resources Act

(Act No 25 of 1999)

» Stipulates assessment criteria and categories of

heritage resources according to their significance (S7)

» Provides for the protection of all archaeological and

palaeontological sites, and meteorites (S35)

» Provides for the conservation and care of cemeteries

and graves by SAHRA where this is not the

responsibility of any other authority (S36)

» Lists activities which require developers any person

who intends to undertake to notify the responsible

heritage resources authority and furnish it with details

regarding the location, nature and extent of the

proposed development (S38)

» South African

Heritage

Resources Agency

(SAHRA)

» Provincial Heritage

Resources

Authority Gauteng

(PHRAG)

An Archaeological Impact Assessment

(Appendix E) has been undertaken and

concluded that the development of the

Clayville Thermal Plant will have an impact of

low significance on archaeological heritage

resources.

In terms of Section 35 of the NHRA no significant

archaeological sites were identified. No further

mitigation prior to construction is recommended

in terms of Section 35 of the NHRA for the

proposed development to proceed.





» Requires the compilation of a Conservation

Management Plan as well as a permit from SAHRA for

the presentation of archaeological sites as part of

tourism attraction (S44)

In terms of the built environment of the area

(Section 34 of the NHRA) no standing structures

older than 60 years occur within the study area.

In terms of Section 36 of the NHRA no burial sites

were recorded.

The project site is located in an industrial area

away from main tourist routes and the Clayville

Thermal Plant will not impact negatively on

significant heritage viewscapes.

A Palaeontological Scoping Study was

undertaken as part of the Scoping Phase. The

study concluded that due to the lack of fossil

heritage within the project site and the low

significance of the impact on the

palaeontological resources no further study is

required. Therefore, the findings of the

Palaeontological Assessment (Appendix E of the

Scoping Report) are considered to be sufficient

and no further Environmental Palaeontological

Impact Assessment is required for the EIA Phase.


Management: Biodiversity Act

(Act No 10 of 2004)

» Provides for the MEC/Minister to identify any process or

activity in such a listed ecosystem as a threatening

process (S53)

» A list of threatened and protected species has been

published in terms of S 56(1) - Government Gazette

29657.

» Three government notices have been published, i.e.

GN R 150 (Commencement of Threatened and

Protected Species Regulations, 2007), GN R 151 (Lists of

Gauteng Department

of Agriculture and

Rural Development

(GDARD)

Through the undertaking of the Ecological Study

(Appendix G of the Scoping Report), which

included the undertaking of a field survey no

species of conservation concern in terms of

NEMBA were identified. Due to the natural

indigenous vegetation within the project site

being severely limited and due to the fact that

this area is so isolated, unstable and small in size,

no Environmental Ecological Impact Assessment





critically endangered, vulnerable and protected

species) and GN R 152 (Threatened or Protected

Species Regulations).

» Provides for listing threatened or protected

ecosystems, in one of four categories: critically

endangered (CR), endangered (EN), vulnerable (VU)

or protected. The first national list of threatened

terrestrial ecosystems has been gazetted, together

with supporting information on the listing process

including the purpose and rationale for listing

ecosystems, the criteria used to identify listed

ecosystems, the implications of listing ecosystems, and

summary statistics and national maps of listed

ecosystems (National Environmental Management:

Biodiversity Act: National list of ecosystems that are

threatened and in need of protection, (G 34809, GN

1002), 9 December 2011).

» This Act also regulates alien and invader species (GN

37885).

is required for the EIA Phase.


Management: Air Quality Act

(Act No 39 of 2004)

» S18, S19 and S20 of the Act allow certain areas to be

declared and managed as “priority areas”.

» Declaration of controlled emitters (Part 3 of Act) and

controlled fuels (Part 4 of Act) with relevant emission

standards.

» The Act provides that an air quality officer may require

any person to submit an atmospheric impact report if

there is reasonable suspicion that the person has failed

to comply with the Act.

» Dust control regulations promulgated in November

2013 may require the implementation of a dust

management plan.

» Government Gazette 33064 of 31 March 2010 provides


Municipality

An Air Emissions License is required to be

obtained from the Metropolitan Municipality for

the Clayville Thermal Plant in terms of the NEM:

Air Quality Act.

Solid fuel combustion installations using solid fuel

for steam generation is Listed Activity (Category

1: Sub-category 1.1) and gas combustion

installations using gas for steam generation is

Listed Activity (Category 1: Subcategory 1.4) in

term of Section 21 of NEM:AQA.

Therefore an AEL must be obtained for the





a list of activities which require an Air Emissions License

and provides the thresholds that need to be complied

with

project.

Conservation of Agricultural

Resources Act (Act No 43 of

1983)

» Prohibition of the spreading of weeds (S5)

» Classification of categories of weeds & invader plants

(Regulation 15 of GN R1048) & restrictions in terms of

where these species may occur.

» Requirement & methods to implement control

measures for alien and invasive plant species

(Regulation 15E of GN R1048).

Department of

Agriculture, Forestry

and Fisheries (DAFF).

The project site is in a disturbed and transformed

state, with most of the vegetative species

comprising of weeds (i.e. Argemone

ochroleuca), pioneers and Invasive Alien Plants

(IAPs)

Measures for the control of invasive vegetation

has been included in the EMPr which is provided

in Appendix H.

National Water Act (Act No 36 of

1998)

» Under S21 of the Act, water uses must be licensed

unless such water use falls into one of the categories

listed in S22 of the Act or falls under the general

authorisation.

» In terms of S19, the project proponent must ensure that

reasonable measures are taken throughout the life

cycle of the project to prevent and remedy the

effects of pollution to water resources from occurring,

continuing, or recurring.

» National Government is the public trustee of the

Nation’s water resources (S3)

» Entitlement to use water (S4) – entitles a person to use

water in or from a water resource for purposes such as

reasonable domestic use, domestic gardening, animal

watering, fire-fighting and recreational use, as set out

in Schedule 1

» Duty of Care to prevent and remedy the effects of

pollution to water resources (S19)

» Procedures to be followed in the event of an

emergency incident which may impact on a water

Department of Water

and Sanitation (DWS)

The development of the Clayville Thermal Plant

will not require a Water Use License or General

Authorisation in terms of the National Water Act

(Act No 36 of 1998) as no water uses will be

triggered.





resource (S20)

» Definition of water use (S21)

» Requirements for registration of water use (S26 and

S34)

» Definition of offences in terms of the Act (S151)


Management: Waste Act (Act

No 59 of 2008)

The Minister may by notice in the Gazette publish a list of

waste management activities that have, or are likely to

have, a detrimental effect on the environment.

The Minister may amend the list by –

» Adding other waste management activities to the list.

» Removing waste management activities from the list.

» Making other changes to the particulars on the list.

In terms of the Regulations published in terms of this Act

(GNR 912), a Basic Assessment or Environmental Impact

Assessment is required to be undertaken for identified listed

activities.

Any person who stores waste must at least take steps,

unless otherwise provided by this Act, to ensure that:

» The containers in which any waste is stored, are intact

and not corroded or in

» any other way rendered unlit for the safe storage of

waste.

» Adequate measures are taken to prevent accidental

spillage or leaking.

» The waste cannot be blown away.

» Nuisances such as odour, visual impacts and breeding

of vectors do not arise; and

» Pollution of the environment and harm to health are

Gauteng Department

of Agriculture and

Rural Development

(GDARD)

No waste management activities listed are

associated with the proposed Clayville Thermal

Plant, therefore no permit is required in this

regard.

Waste handling, storage and disposal during

construction and operation is required to be

undertaken in accordance with the

requirements of the Act, as detailed in the EMPr

(refer to Appendix H).





prevented.

National Forests Act (Act No 84

of 1998)

» According to this Act, the Minister may declare a tree,

group of trees, woodland or a species of trees as

protected. The prohibitions provide that ‘no person

may cut, damage, disturb, destroy or remove any

protected tree, or collect, remove, transport, export,

purchase, sell, donate or in any other manner acquire

or dispose of any protected tree, except under a

license granted by the Minister’.

» GN 908 of 21 November 2014 provides a list of

protected tree species.

» Department of

Agriculture,

Forestry and

Fisheries (DAFF).

» Gauteng

Department of

Agriculture and

Rural

Development

(GDARD)

A permit or license is required for the destruction

of protected tree species and/or indigenous tree

species. No protected tree species have been

identified within the project site and therefore no

permit is required from DAFF.

The Hazardous Substances Act

No. 15 of 1973

» This Act was promulgated to provide for the control of

substances which may cause injury or ill-health to, or

death of, humans by reason of their toxic, corrosive,

irritant, strongly sensitising or flammable nature.

» The Hazardous Substances Act also provides for

matters concerning the division of such substances or

products into groups in relation to the degree of

danger, the prohibition and control of the importation,

manufacture, sale, use, operation, application and

disposal of such substances and products.

» Department of

Health

» Ekurhuleni

Metropolitan

Municipality.

It is necessary to identify and list all the Group I, II,

III and IV hazardous substances that may be

utilised on the Clayville Thermal Plant project site

and in what operational context they are used,

stored or handled. If applicable, a license is

required to be obtained from the Department of

Health and/or the Ekurhuleni Metropolitan

Municipality.

Provincial Legislation

Gauteng Noise Control

Regulations (1999)

Acknowledges the role of the Gauteng Province to take

effective measures to support local government. The

document aims to:

» Provide a uniform minimum standard for noise

regulation in the Province;

» Accommodate the specific circumstances of different

neighbourhoods and areas; and

» Create new mechanisms for effective enforcement in

neighbourhoods.


Municipality.

Noise impacts are expected to be associated

with the construction and operation phases of

the project and are not likely to present a

significant intrusion to the local community,

which is located more than 1 km from the site.

There is therefore no requirement for a noise

permit in terms of the legislation.





In the Gauteng Noise Control Regulations of 1999, a

disturbing noise refer to a noise level that causes the

ambient noise level to rise above the designated zone

level, or if no zone level has been designated, the typical

rating levels for ambient noise in districts, indicated in table

2 of SABS 0103.

Gauteng Provincial

Environmental Management

Framework (2014)

The Gauteng Provincial Environmental Management

Framework is a legal instrument in terms of the

Environmental Management Framework Regulations, 2010.

The purpose of the regulations is to assist environmental

impact management including EIA processes, spatial

planning and sustainable development.

The objective of the framework is to promote efficient

urban development (including associated service

infrastructure) in defined selected areas with lower

environmental concerns and high development demand.

Gauteng Department

of Agriculture and

Rural Development

(GDARD)

The development of the Clayville Thermal Plant

will aid in the promotion of sustainable

development within an area where there are

low environmental concerns (i.e. highly

transformed industrialised area) and high

development demand. The Clayville Thermal

Plant falls within Zone 5 which is the industrial and

commercial development focus zone. The

development is therefore compliant with the

relevant planning for the area. No further

compliance requirements are applicable.

Service Delivery Charter and

Standards for the Gauteng

Department of Agriculture,

Conservation and Environment

(2014)

The following strategic objectives must be implemented:

» The facilitation of sustainable development in Gauteng

by ensuring sustainable land uses (including

infrastructure development) and land use patterns.

» To contribute to sustainable development and quality

of life by promoting a safe and healthy living

environment.

Gauteng Department

of Agriculture and

Rural Development

(GDARD)

The Clayville Thermal Plant will be developed on

a project site zoned for Industrial Use.

Guideline Documents / Standards / Plans

SANS 69 - South African National

Standard - Framework for setting

& implementing national

ambient air quality standards,

SANS 1929 - South African

National Standard - Ambient Air

» The South African Bureau of Standards (SABS), through

a technical committee, developed ambient air quality

limits based on international best practice for

particulate matter less than 10 µm in aerodynamic

diameter (PM10), dust fallout, sulphur dioxide, nitrogen

dioxide, ozone, carbon monoxide, lead and benzene.


Municipality

The recommendations that the standards make

are likely to inform decisions by authorities, but

non-compliance with the standards will not

necessarily render an activity unlawful.





Quality - Limits for common

pollutants.

These ambient limits were derived from international best

practice and what was regarded to be achievable in the

South African context, taking both the natural environment

and socio-economic status into account. The SANS limits

informed the newly promulgated SA Standards




4.5.1 International Guidelines

i. The Equator Principles III (June, 2013)

The Equator Principles (EPs) III constitute a financial industry benchmark used for determining, assessing,

and managing projects environmental and social risks. The EPs are primarily intended to provide a

minimum standard for due diligence to support responsible risk decision-making. The EPs are applicable to

large infrastructure projects and apply globally to all industry sectors.

The EPs comprise the following principles:

Principle 1: Review and Categorisation

Principle 2: Environmental and Social Assessment.

Principle 3: Applicable Environmental and Social Standards.

Principle 4: Environmental and Social Management System and Equator Principles Action Plan

Principle 5: Stakeholder Engagement

Principle 6: Grievance Mechanism

Principle 7: Independent Review

Principle 8: Covenants

Principle 9: Independent Monitoring and Reporting

Principle 10: Reporting and Transparency.

When a project is proposed for financing, the Equator Principle Financial Institution (EPFI) will categorise it

based on the magnitude of its potential environmental and social risks and impacts.

Projects can be categorised as follows:

Category A: Projects with potential significant adverse environmental and social risks and/or impacts

that are diverse, irreversible or unprecedented.

Category B: Projects with potential limited adverse environmental and social risks and/or impacts that

are few in number, generally site-specific, largely reversible and readily addressed through mitigation

measures.

Category C: Projects with minimal or no adverse environmental and social risks and/or impacts.

Category A and Category B projects require that an assessment process be conducted to address the

relevant environmental and social impacts and risks associated with the project. Such an assessment may

include the following where applicable:

» An assessment of the baseline environmental and social conditions.

» Consideration of feasible environmentally and socially preferable alternatives.

» Requirements under host country laws and regulations, applicable international treaties and

agreements.

» Protection and conservation of biodiversity (including endangered species and sensitive ecosystems in

modified, natural and Critical Habitats) and identification of legally protected areas.

» Sustainable management and use of renewable natural resources (including sustainable resource

management through appropriate independent certification systems).

» Use and management of dangerous substances.




» Major hazards assessment and management.

» Efficient production, delivery and use of energy.

» Pollution prevention and waste minimisation, pollution controls (liquid effluents and air emissions), and

solid and chemical waste management.

» Viability of Project operations in view of reasonably foreseeable changing weather patterns/climatic

conditions, together with adaptation opportunities.

» Cumulative impacts of existing Projects, the proposed Project, and anticipated future Projects.

» Respect of human rights by acting with due diligence to prevent, mitigate and manage adverse

human rights impacts.

» Labour issues (including the four core labour standards), and occupational health and safety.

» Consultation and participation of affected parties in the design, review and implementation of the

Project.

» Socio-economic impacts.

» Impacts on Affected Communities, and disadvantaged or vulnerable groups.

» Gender and disproportionate gender impacts.

» Land acquisition and involuntary resettlement.

» Impacts on indigenous peoples, and their unique cultural systems and values.

» Protection of cultural property and heritage.

» Protection of community health, safety and security (including risks, impacts and management of

Project’s use of security personnel).

» Fire prevention and life safety.

Such an assessment should propose measures to minimise, mitigate, and offset adverse impacts in a

manner relevant and appropriate to the nature and scale of the proposed Project. In terms of the EPs

South Africa is a non-designated country, and as such the assessment process for projects located in South

Africa evaluates compliance with the applicable IFC PSs on Environmental and Social Sustainability and

the World Bank Group (WBG) EHS Guidelines.

The Clayville Thermal Plant is currently being assessed in accordance with the requirements of the

amended 2014 EIA Regulations (GNR 326), published in terms of Section 24(5) of the National

Environmental Management Act (No. 107 of 1998) (NEMA), which is South Africa’s national legislation

providing for the authorisation of certain controlled activities. Through this assessment, all potential social

and environmental risks have been identified and assessed, and appropriate mitigation measures

proposed.

ii. International Finance Corporation (IFC) Performance Standards on Environmental and Social

Sustainability (January 2012)

The International Finance Corporation’s (IFC) Performance Standards (PS) on Environmental and Social

Sustainability were developed by the IFC and were last updated on 1 January 2012. The overall objectives

of the IFC PS are:

» To fight poverty.

» To do no harm to people or the environment.

» To fight climate change by promoting low carbon development.

» To respect human rights;

» To Promote gender equity;




» To provide information prior to project development, free of charge and free of external manipulation;

» To collaborate with the project developer to achieve the PS;

» To provide advisory services; and

» To notify countries of any Trans boundary impacts as a result of a Project.

The PS comprise of the following:

Performance Standard 1: Assessment and Management of Environmental and Social Risks and

Impacts.

Performance Standard 2: Labour and Working Conditions.

Performance Standard 3: Resource Efficiency and Pollution Prevention.

Performance Standard 4: Community Health, Safety and Security.

Performance Standard 5: Land Acquisition and Involuntary Resettlement.

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural

Resources.

Performance Standard 7: Indigenous Peoples.

Performance Standard 8: Cultural Heritage.

Performance Standard 1 establishes the importance of:

i). Integrated assessment to identify the social and environmental impacts, risks, and opportunities of

projects.

ii). Effective community engagement through disclosure of project-related information and consultation

with local communities on matters that directly affect them.

iii). The management of social and environmental performance throughout the life of a project through

an effective Environmental and Social Management System (ESMS).

PS 1 requires that a process of environmental and social assessment be conducted, and an ESMS

appropriate to the nature and scale of the project and commensurate with the level of its environmental

and social risks and impacts be established and maintained. PS 1 is the overarching standard to which all

the other standards relate. PS 2 through 8 establish specific requirements to avoid, reduce, mitigate or

compensate for impacts on people and the environment, and to improve conditions where appropriate.

While all relevant social and environmental risks and potential impacts should be considered as part of the

assessment, PS 2 through 8 describe potential social and environmental impacts that require particular

attention in emerging markets. Where social or environmental impacts are anticipated, the developer is

required to manage them through its Environmental and Social Management System (ESMS) consistent

with PS 1.

iii. The IFC Environmental Health and Safety (EHS) Guidelines

The IFC EHS Guidelines are technical reference documents with general and industry specific examples of

Good International Industry Practice (GIIP). The IFC EHS General Guideline has relevance to the proposed

project.

The General EHS Guidelines are designed to be used together with the relevant Industry Sector EHS

Guidelines. The EHS Guidelines’ general approach to air quality states that projects should prevent or

minimise impacts by ensuring that:




» Emissions do not result in pollutant concentrations that reach or exceed the relevant national ambient

air quality guidelines and standards, or in their absence, the current World Health Organisation (WHO)

Air Quality Guidelines (AQG) or other internationally recognised sources;

» Emissions do not contribute a significant portion to the attainment of relevant ambient AQG or

standards. The Guideline suggests 25% of the applicable ambient air quality standards to allow

additional, future development in the same airshed.

The IFC EHS Guidelines contain the performance levels and measures normally acceptable to the IFC and

are generally considered to be achievable in new facilities at reasonable costs. When host country

regulations differ from the levels and measures presented in the EHS Guidelines, projects are expected to

achieve whichever standard is more stringent.

The General EHS Guidelines state that at project level, impacts should be estimated through qualitative or

quantitative assessments by the use of baseline air quality assessments and atmospheric dispersion models.

The dispersion model should be internationally recognised and able to take into account local

atmospheric, climatic and air quality data as well as the effects of downwash, wakes or eddy effects

generated by structures and terrain features.

The General EHS Guidelines also provides guidance with respect to:

» Projects located in degraded airsheds or ecologically sensitive areas;

» Points sources and stack heights;

» Emissions from small combustion facilities (3 to 50 MWth rated heat input capacity);

» Fugitive sources;

» Ozone depleting substances;

» Land based mobile sources;

» Greenhouse gases;

» Monitoring; and

» Air emissions prevention and control technologies



Description of the Receiving Environment Page 72

CHAPTER 5: DESCRIPTION OF THE RECEIVING ENVIRONMENT

This section of the EIA Report provides a description of the environment that may be affected by the

Clayville Thermal Plant. This information is provided in order to assist the reader in understanding the

receiving environment within which the proposed development is situated. Aspects of the biophysical,

social and economic environment that could be directly or indirectly affected by, or could affect, the

proposed development have been described. This information has been sourced from both existing

information available for the area as well as collected field data, and aims to provide the context within

which this EIA is being conducted. A comprehensive description of each aspect of the affected

environment is included within the specialist reports contained within the Appendices D - F.



This chapter of this final EIA Report includes the following information required in terms of Appendix 3:

Content of the Environmental Impact Assessment Report:


(h)(iv) the environmental attributes

associated with the development footprint

alternatives focusing on the geographical,

physical, biological, social, economic,

heritage and cultural aspects

The environmental attributes associated with the development of

the Clayville Thermal Plant is included as a whole within this chapter.

A comprehensive description of each aspect of the affected

environment is included within the specialist reports contained within

the Appendices D - F.

5.2 Regional Setting: Location of the Project Site

The Gauteng Province is the smallest province in South Africa covering an area of approximately

18 178 km² and supporting approximately 13 million people. The province shares the boundaries with the

Mpumalanga, Limpopo, North West and Free State Provinces. The proposed development falls within the

Clayville industrial area near Olifantsfontein under the jurisdiction of the Ekurhuleni Metropolitan

Municipality. It is one of three metropolitan municipalities that form part of the Gauteng Province.

Erf 459 is currently used for industrial purposes (i.e. offices and ware-housing) and is devoid of natural

vegetation. Erf 457 and Erf 12 of 508 are currently vacant land and are in a disturbed and transformed

state, with most of the vegetative species comprising of weeds, pioneers and Invasive Alien Plants (IAPs).

All three properties are currently zoned as Industrial 1.

The broader study area within the Clayville Industrial Area is bordered by mixed-use of industrial

developments as well as open areas. There are two residential areas situated near the project site, i.e.

Clayville East (~1.1km east) and Tswelapele (~1.8km west). The regional road, R562, is situated

approximately 500m south east of the project site. The N1, situated west of the project site, carries

significant traffic each day. A railway line servitude traverses the centre of the project site. The railway line

has however been decommissioned and is no longer in use. There are three substations within a 700m

radius of the proposed site (i.e. the Clayglass 88/11kV Substation, the Consol 88kV Substation and the

Clayville Four 88/11/6.6kV Substation), which adds to the industrial nature of the area and the project site.




Agricultural activities, mainly relating to cultivation are located ~3,5km east and 4km north-west of the

project site.

5.3 Climatic Conditions

Temperature:

Specific data related to Olifantsfontein and Clayville was unavailable during the time this report was

compiled, and therefore data from OR Tambo International Airport (located 18km south from the site) was

used to represent the climatic conditions of the project site and surrounding area.

This region of Gauteng experiences a temperate Highveld climate with warm summers and mild winters.

Rainfall predominantly occurs in summer. The climate of this region of Gauteng has the following

characteristics i) the mean annual rainfall is about 60mm, with January typically being the wettest month,

averaging at about 125mm, and July being the driest with an average of only 4mm; ii) the average annual

temperature in this area is 16°C, with January being the warmest (ave. 20.1°C) and June being the coldest

(ave. 10.1°C).

Wind conditions:

Winds within this region are considered to be light to moderate and are typically less than 8 m/s but

stronger winds can occur. A windrose is used to depict the frequency of occurrence of wind from the 16

cardinal wind directions as well as define wind speed classes (refer to Figure 5.1). The wind direction is

predominantly west-northwest to east-northeast.

Dispersion:

The dispersion potential of an area experiences both diurnal and seasonal variation. During the day,

radiation is stronger in the summer than in winter and the dispersion potential is generally better on summer

days than winter days. Thermal turbulence disappears when the sun sets, and mechanical turbulence

decreases as the wind speeds drops at night. At night, as the surface temperature inversion develops, the

lowest layer of the atmosphere becomes more and more stable, reaching a maximum stability at sunrise

when the inversion is strongest and deepest. As a result, the dispersion potential is inhibited during the

night and the poorest dispersion conditions generally occur at sunrise. Pollutants tend to accumulate near

the point of release under these conditions, particularly when released close to ground level. The

dispersion potential is generally poorer during winter nights than summer nights.

Over Gauteng, the dispersion potential is relatively poor and particularly so in winter. Anticyclonic

circulation prevails and the associated subsidence is conducive to the formation of elevated temperature

inversions with base heights between 2000 m and 3000 m above ground level in summer and 1700 m

above ground level in winter (Tyson et al, 1988). The anticyclonic conditions are ideal for the formation of

surface-based temperature inversions. Tyson et al (1976) indicated winter surface inversions varying from 5

to 7°C in strength and 300 to 500 m in depth over the Highveld. In summer, the depths are similar to winter

but the strength seldom exceeded 2°C.




Figure 5.1: Windrose depicting annual wind direction and speed at OR Tambo in m/s (obtained from

Meteoblue https://www.meteoblue.com/). Wind speed is given in m/s, and each arc

represents a frequency of occurrence of 500 hours. There are 8 760 hours in a year.

5.4 Biophysical Characteristics of the Study Area

5.4.1 Geology

The oldest rocks in the area are the basement rocks of the Johannesburg Dome to the west of the project

site. These rocks include ultramafic rocks, gneiss, migmatite and granodiorite. To the east, north and south

of the project site are a variety of ancient rocks of the Witwatersrand Supergroup and the Pretoria Group,

ranging in age from 3340 to 2150 Ma (million years). These rocks are all volcanic (produced by early

volcanic activity, i.e. igneous rock that came up to the surface) or plutonic (igneous rock that solidified far

below the earth’s surface) in origin.

Figure 5.2 provides an illustration of the geology of the surrounding area and the project site. To the south

east of the project site is an outlier of the Karoo Supergroup sediments, namely sandstones, shales and

coals of the Early Permian Ecca, Vryheid Formation.




Figure 5.2: Geological map of the area around Clayville Thermal Plant (indicated by black circle).

Map enlarged from the Geological Survey 1: 1 000 000 map 1984. Abbreviations of the rock

types are explained in Table 5.1 below.

According to regional geological mapping, the project site falls within the Malmani Subgroup

(Chuniespoort Group, Transvaal Supergroup), which consists of variable weathered dolomite. The

weathered dolomite is commonly intruded by syenite sills and dykes. It is expected that the project site is

likely to be underlain by chert-rich dolomite Monte Christo Formation of the Malmani Subgroup, as

opposed to the chert-poor dolomite of the Lyttleton Formation. Due to the geological setting of the

project site, there is a risk of sinkholes forming anywhere on-site.

Table 5.1: Explanation of symbols for the geological map and approximate ages (Barbolini et al., 2016;

Erikssen et al., 2006. Johnson et al., 2006; McCarthy, 2006; van der Westhuizen et al., 2006).

SG = Supergroup; Fm = Formation.

Symbol Group/Formation Lithology Approximate Age

Jd Jurassic dolerite dykes Dolerite Ca 180 Ma

Pv Vryheid Fm, Ecca Group Sandstone, shale, coal Early Permian 296-269 Ma

C-Pd Dwyka Tillite, sandstone, mudstone,

shale

Upper Carboniferous, Early

Permian 295-290 Ma

Vsi Silverton Fm, Pretoria Group Basalt, tuff, shale Ca 2150 Ma

Vhd Dwaalheuvel, Strubenkop and

Daspoort Fms; Pretoria Group

Andesite, sandstone, shale




Symbol Group/Formation Lithology Approximate Age

Vh Hekpoort Fm, Pretoria Group Basaltic andesite, pyroclastic

rocks

2224 Ma

Vti Timeball Hill and Rooihoogte

Fm, Pretoria Group

Shale, quartzite, conglomerate,

breccia, diamictite

Ca 2420 Ma

Vm Malmani subgroup,

Chuniespoort Group

Dolomite, chert 2642 – 2500 Ma

Vbr Black Reef Fm Quartzite, conglomerate, shale,

basalt

>2642 Ma

Vdi Diabase Diabase

Rk Klipriviersberg Group,

Ventersdorp Supergroup

Mafic and felsic lavas,

quartzites, shales

conglomerates

Late Archaean

>2700 Ma

Rw Witwatersrand Supergroup

(undifferentiated)

Quartzite, shale Ca 2950 – 2750 Ma

Rt Turfontein Subgroup, Central

Rand Group, Witwatersrand SG

Conglomerate, quartzite

Rjo Johannesburg Subgroup,

Central Rand group,

Witwatersrand SG

Quartzite, conglomerate, shale

Rg Government Subgroup, West

Rand Group, Witwatersrand SG

Quartzite, shale

Rh Hospital Hill, West Rand Group,

Witwatersrand SG

Shale, quartzite

Z, Zhh Basement complex of the

Johannesburg Dome

Gneiss, migmatite, granodiorite 3340 Ma

5.4.2 Soils and Agricultural Potential

Soil within the study area is expected to be clayey silty sand of an Aeolian/hillwash origin with a colluvial

pebble marker separating the transported and residual profile. Thick chert-rich residuum consisting of small

through large boulders in a clayey silty sand matrix, underlain by highly and deeply weathered and

leached, dolomite bedrock which is penitentially intruded by syenite.

The land capability for the project site is classified as land type Class III (unsuitable for crop production).

The area south-west of the project site is classified as having severe limitations regarding crop production

(Class VI). No agricultural activities are being undertaken within the broader study area or within the

project site.

5.4.3 Ecological Profile

Protected and conservation areas:

According to the Gauteng Conservation Plan Version 3.3 the proposed project site does not fall within any

CBA areas. The project site however borders a narrow strip of open space classified as an Ecological

Support Area (ESA). An ESA is also present south east of the affected properties. The closest CBA area is

located approximately 900m to the east of the affected properties (east of the Clayville East residential




area and the M57 Road). This CBA is regarded as an Important Area due to the potential habitat

provided for Red Listed plant species as well as the presence of primary vegetation within this area.

Vegetation:

The project site is situated in the Grassland biome and Dry Highveld Grassland Bioregion. The vegetation in

and surrounding the project site is Carletonville Dolomite Grassland (Gh15). This vegetation type has been

classified as Vulnerable, although it is not included within the National List of Ecosystems that are

Threatened and in need of protection (GN1002 of 2011), published under the National Environment

Management: Biodiversity Act (Act No. 10 of 2004).

A species list from POSA (http://posa.sanbi.org, Grid reference 2528CC) containing the species that have

been recorded to date in the area was obtained. A total of 894 indigenous species have been recorded

in the 2528CC Quarter Degree Grid according to the SANBI database.

The proposed project site are situated within a relative dense industrial area, with most of the landscape

being transformed, comprising of hard surfaces and largely built up areas. Erf 457 is in a similar condition

comprising out of standing infrastructure, hard surfaces and areas devoid of natural vegetation. This

property contains no natural elements and furthermore likely do not sustain any natural biodiversity and

ecological services. Erf 459 and Portion12 of Erf 508 are currently not developed and contain some form of

vegetation. These two properties cumulatively cover an area of approximately 0.96ha. These properties

are in a disturbed and transformed state, with most of the vegetative species comprising of weeds (i.e.

Argemone ochroleuca), pioneers and Invasive Alien Plants (IAPs). Bare patches, devoid of vegetation, are

also present within these two properties and has resulted in soil compaction and some sheet erosion.

Building rubble have also been dumped within these areas.

The natural indigenous vegetation within the project site is severely limited and due to the fact that this

area is so isolated, unstable and small in size it is highly unlikely that at any time in the future this area will

naturally re-establish a satisfactory natural vegetation cover, sustaining natural biodiversity and processes.

Fauna:

Of the 50 species recorded within the degree grid, 5 species are highly likely and 6 species are likely to

occur within and/or within the immediate surroundings. Six species have a slight potential to occur within

this area. Most of these species that are likely to occur within the project site will most likely not reside

permanently within the project site but rather move through the area. None of these species likely to be

found within the area are Red List species. The only potential red list mammal species that may inhabit the

surrounding environment is the South African Hedgehog – Atelerix frontalis (Near Threatened) although no

suitable habitat is present within the affected properties and the occurrence of this species within these

properties is highly unlikely. Most likely mammals to inhabit the project site as well as immediate

surrounding environment include mostly cosmopolitan (introduced) species such as domestic cat – Felis

catus; Mauritian Tomb Bat – Taphozous mauritianus; Geoffroy’s Horseshoe Bat – Rhinolophus clivosus,

Yellow-bellied House Bat – Scotophilus dinganii, House mouse – Mus musculus and House rat – Rattus rattus.




5.5 Access and Transport Routes in the Region

The Clayville industrial area is located between the R562 (also referred to as the Olifantsfontein Road) to

the south of the project site, South View Road to the north of the project site and the M18 (Main Road) to

the east of the project site. These two-lane arterial roads are characterised by signalised intersections and

provide access links to the broader road network as below:

» The R562 forms an important road link between the N1 to the west of the Clayville industrial area and

the R21 to the east of Clayville industrial area.

» The M18 is a north-south orientated route, with mostly industrial related traffic in the vicinity of the

Clayville industrial area and lighter traffic volumes north of South View Road. The M18 provides access

to the R562 situated to the south and to Nellmapius Drive to the north of the Clayville industrial area.

» South View Road is a connector link between the R562 and the M18. A high percentage of traffic on

this road link is generated by Clayville industrial area.

» The Clayville industrial area road network in the vicinity of the project site is typical to many industrial

developments, comprising 8m wide two-lane roads centrally located in 25 metres wide road reserves.

These roads are characterised by a high number of site accesses, unkept road verges and a lack of

pedestrian facilities, apart from Nut Avenue that provides a paved sidewalk for pedestrians (along the

northern road edge).

Access to the site is possible via Spanner Road situated west of the project site and from Industrial Road

situated east of the project site. These north-south orientated roads junction with South View Road,

approximately 1km to the north of the project site. Nut Avenue and Nail Avenue provide east-west

orientated links between Spanner and Industry Roads.

5.6 Air Quality

The identification of current sources of emissions in the area and the characterisation of existing ambient

pollutant concentrations is fundamental to understand the current air quality of the area. The Ekurhuleni

Metropolitan Municipality (EMM) covers an extensive area from Germiston in the west to Springs and Nigel

in the east. There are nearly 180 recorded industrial facilities in the EMM that operate Listed Activities.

Traffic in the municipality is significant with highway connections to major cities such as Johannesburg,

Tshwane and Durban. OR Tambo International Airport is situated within the eastern part of Johannesburg

within the EMM. There are also mining activities within the municipality. Air pollution sources specifically in

the Clayville industrial area include industrial activity and motor vehicle emissions.

The municipality operates eleven (11) ambient air quality monitoring stations, including a monitoring

station at Olifantsfontein. These monitoring stations collect hourly data on pollutants including SO2, NO2

and particulates. Ambient PM10 concentrations exceed the National Ambient Air Quality Standard

(NAAQS) throughout the municipality, while there are frequent exceedances of the NAAQS for NO2.

Figure 5.3 illustrates hourly NO2 and SO2 concentrations at Olifantsfontein in parts per billion (ppb). The

annual average SO2 concentrations at the Olifantsfontein monitoring station are well below the National

Ambient Air Quality Standards (NAAQS) of 19 ppb since 2014. The annual average NO2 concentrations at

Olifantsfontein are relatively high and exceeded the NAAQS of 19 ppb in 2014 and 2016. Table 5.2

indicates the annual average concentrations of SO2 and NO2 concentrations at Olifantsfontein measured

in ppb.




Figure 5.3: Illustrate hourly NO2 (left) and SO2 (right) concentrations at Olifantsfontein in ppb. The limit

value of the NAAQS is shown by the red lines.

Table 5.2: Annual average concentrations of SO2 and NO2 concentrations.

NO2 SO2

2014 35.1 8.8

2015 5.3

2016 21.9 6.2

2017 12.0 4.0

Sensitive receptors:

Residential areas are commonly classed as sensitive receptors as people generally spend more time at

home than elsewhere. Potentially sensitive receptors to the Clayville Thermal Plant are therefore any

residential areas relatively close to the facility, and particularly those in the downwind sector that may be

affected by emissions from the proposed thermal plant. The downwind sector from the thermal plant is

predominantly east-southeast to west-southwest of the facility, i.e. downwind under the prevailing west-

northwest to east-northeast wind conditions.

There are two residential areas relatively close to the project site in the downwind zone. These include

Clayville East which is situated 1.1km to the east and north east, and Tswelapele, ranging from

approximately 1.8km to the north west of the plant. The town of Clayville is located approximately 1.8km to

the north-northeast, upwind of the proposed thermal plant.

5.7 Heritage features of the region

5.7.1 Heritage and archaeology

South Africa has a long and complex Stone Age sequence of more than 2 million years. The broad

sequence includes the Later Stone Age, the Middle Stone Age and the Earlier Stone Age. Each of these

phases contains sub-phases or industrial complexes, and within a regional variation regarding

characteristics and time ranges can be expected. The three main phases can be divided as follows:

» Later Stone Age (LSA); associated with Khoi and San societies and their immediate predecessors.

Recently to ~30 thousand years ago.




» Middle Stone Age (MSA); associated with Homo sapiens and archaic modern humans. 30-300

thousand years ago.

» Earlier Stone Age (ESA); associated with early Homo groups such as Homo habilis and Homo erectus.

400 000-> 2 million years ago.

Stone Age:

Remains dating to all three of these phases were recorded at the Boulders Shopping Centre

approximately 10km south west of the proposed project site, by Mason (1997). The Melville Koppies is a

MSA site and is located ~34km from the project site (Bergh 1999: 4). This broader area was also considered

to be significant to Iron Age communities, since these people had smelted and worked iron ore at the

Melville Koppies site since the year 1060, by approximation (Bergh 1999: 7, 87). MSA and LSA material was

also recorded at Glennferness cave in Johannesburg. Evidence that the larger area was utilised by Stone

Age communities includes ESA and MSA tools, which were recorded along the Kliprivier.

Iron Age:

The Iron Age of the region consists of Tswana speaking people who settled in the area from the early 16th

century. The Iron Age is characterised by the ability of early people to manipulate and work Iron ore into

implements that assisted them in creating a favourable environment to make a better living.

The Smelting Site at Melville Koppies was excavated by Professor Mason from the Department of

Archaeology of the University of Witwatersrand in the 1980s. Extensive stone-walled sites are also recorded

further south at Klipriviers Berg Nature Reserve belonging to the Late Iron Age period. These sites are now

collectively referred to as Klipriviersberg (Huffman, 2007). The settlements are complex in that aggregated

settlements are common, the outer wall sometimes includes scallops to mark back courtyards, there are

more small stock kraals, and straight walls separate households in the residential zone. These sites date to

the 18th and 19th centuries and was built by people in the Fokeng cluster.

In this area, the Klipriviersberg walling would have ended at approximately AD 1823, when Mzilikazi

entered the area (Rasmussen, 1978). This settlement type may have lasted longer in other areas because

of the positive interaction between Fokeng and Mzilikazi.

The Difaqane (Sotho), or Mfekane was a time of bloody upheavals in KwaZulu-Natal and in the Highveld,

which occurred around the early 1820’s until the late 1830s. This was in response to heightened

competition for land and trade, and caused population groups like gun-carrying Griquas and Shaka’s

Zulus to attack other tribes. In 1827, Mzilikazi’s Ndebele started moving through the area where

Johannesburg is located today. This group went on raids to various other areas in order to expand their

area of influence (Bergh, 1999). These settlements are complex in that aggregated settlements are

common, and the outer wall sometimes includes scallops to mark back courtyards. There are also small

stock kraals and straight walls separate households in the residential zone. These sites date to the 18th and

19th centuries and was built by people in the Fokeng cluster. In this area, the Klipriviersberg walling would

have ended at about AD 1823, when Mzilikazi entered the area (Rasmussen, 1978). This settlement type

may have lasted longer in other areas due to the positive interaction between Fokeng and Mzilikazi.




Historical Information:

During the time of the Difaqane, a northwards migration of white settlers from the Cape was taking place.

Some travellers, missionaries and adventurers had gone on expeditions to the northern areas in South

Africa as early as the 1720s. It was however only by the late 1820s that a mass-movement of Dutch

speaking people in the Cape Colony started advancing into the northern areas. This was due to feelings

of mounting dissatisfaction caused by economical and other circumstances in the Cape. This movement

later became known as the Great Trek. This migration resulted in a massive increase in the extent of that

proportion of modern South Africa dominated by people of European descent (Ross, 2002). By 1939 to

1940, farm boundaries were drawn up in an area that includes the present-day Johannesburg and

Krugersdorp (Bergh, 1999).

The first settlers moved within the Midrand area in the 1820s, and included hunters, traders, missionaries and

other travellers. Voortrekker farmers such as Frederik Andries Strydom and Johannes Elardus Erasmus

established the farms Olifantsfontein and Randjesfontein respectively around the 1840’s and this indicated

permanent occupation of the area by white settlers. These early settlers and their descendants were often

buried on their farms and formal and informal graves and graveyards can be expected anywhere on the

landscape (Van Schalkwyk, 1998).

The Anglo-Boer War (1899-1902) also impacted the Midrand area as the area was a key focus of the British

war effort for a short period of time when the British forces under Lord Roberts advanced through Midrand

from Johannesburg while travelling to Pretoria. Pretoria was occupied on 5 June 1900. Some British military

units were stationed close to the project site which now includes the Eskom Academy of Learning (~8km

south west). No major battles took place in Midrand and conflict in the area was defined by the Boer

attempts to sabotage the railway line as well as attacks on troop trains. A notable incident was the

successful Boer demolition of the railway culvert near the Pinedene Station (Van Schalkwyk, 1998). During

this time, there was also a Black Concentration Camp built by the British near Olifantsfontein

station/railway (Bergh, 1999).

The general area under investigation has a wealth of heritage sites and a cultural layering including LSA

scatters and numerous grave sites and cemeteries. None of these sites are located within or close to the

project site but provides an indication of sites that can be expected in the area.

5.7.2 Palaeontology (Fossils)

The Black Reef Formation and Malmani Subgroup contain banded ironstone and dolomites, which were

formed by the chemical activities of ancient algae, photosynthesis and oxygen production. This formation

aren’t known to have preserved fossil algae near Olifantsfontein. Some formations within the ancient

Pretoria Group represent marginal marine or lacustrine deposits with trace fossils of microbial mats and

some ripple marks, for example the Daspoort and Magaliesberg Formations, but not the particular

formations occurring in the Olifantsfontein area.

The Dwyka Formation represents the receding glacial deposits from the Upper Carboniferous and Early

Permian, a time period when land plants were abundant in the warmer regions to the far north of Brakpan.

Rare Dwyka fossils (Glossopteris leaves, Stigmaria roots, lycopods and sphenophytes) have been reported

from near Vereeniging, about 75-100km southwest of Olifantsfontein. No fossil plants of the Glossopteris

flora have been reported from the Vryheid Formation around Olifantsfontein. All these rock formations are

too old for vertebrate body fossils.




There is a possibility that there are refractory clays at the base of the Vryheid Formation, especially given

the name of the area, similar to the ones recorded to the south west and south east of the Rand. Although

clay deposits are fairly common, they seldom preserve fossil plants, the exception being the Lawley brick

quarry near Lenasia (Bredell, 1978, Anderson and Anderson, 1985).

5.8 Social and Economic Characteristics of the Project Site and Surrounding Areas

The EMM is considered to be one of the most densely populated areas in the province and in the country

and includes Germiston in the west and Springs and Nigel in the east. Other cities/towns included in the

municipality include Alberton, Edenvale, Kempton Park and Tembisa. The EMM covers an area of over

975km² and is regarded as the transportation hub of the country as it is home to OR Tambo International

Airport, South Africa's largest railway hub; several modern freeways and expressways and the Maputo

Corridor Development (Municipalities of South Africa, 2012-2017).

The Ekurhuleni Metropolitan Municipality is classified as a Category A municipality which means that the

municipality governs major city regions. Approximately 23% of the economy consists of manufacturing,

22% of finance and business services, 19% of community services and 11% of transport. The diverse

economy in the region accounts for almost a quarter of the province’s economy and is often referred to

as “Africa’s Workshop”. Key projects in the municipality include:

» Ekurhuleni Aerotropolis Development;

» Revitalisation of the manufacturing sector;

» Integrated Rapid Public Transport System (IRPTN);

» Digital City; and

» Revitalisation of township economies.

Baseline Characteristics of the Ekurhuleni Metropolitan Municipality:

General baseline characteristics and challenges of the ULM are as follows (Statistics South Africa, 2011):

» The municipality has a population of ~3 178 470.

» Of the ~3 178 470 population, about 48.79% are female, while 51.21% are male.

» More than 78% of the population comprise the Black African ethnic group and 15.8% comprise the

white ethnic group.

» The municipality has a growth rate of 2.47%.

» The level of education influences growth and economic productivity of a region. In the municipality

3% of the population have no schooling, 35.8% had some form of primary education, 19.4% have

completed matric and only 3.8% of the population have higher education. This means that majority of

the population have a low-skill level and would need job employment in low-skill sectors.

» The unemployment rate is high at 28.8% (in 2011).

» The Economically Active Population (EAP) (individuals that are aged 15-64 that are either employed or

actively seeking employment) accounts for 71.7% of the entire population.



Assessment of Impacts Page 83

CHAPTER 6: ASSESSMENT OF POTENTIAL IMPACTS

This chapter serves to assess the significance of the positive and negative environmental impacts (direct

and indirect) expected to be associated with the development of the Clayville Thermal Plant and

associated infrastructure. Cumulative environmental impacts associated with the development of the

project are assessed separately within Chapter 7. This assessment has been undertaken for all the phases

of the project’s development and for all the project components which include the following:

» CFB Boiler;



area;


» Condenser on-site for the conversion of steam back to water;











office.

The full extent of the project site was considered through the Scoping Phase of the EIA process. On-site

sensitivities and potential impacts were identified through the review of existing information, desktop

evaluations, on-site inspections of impacts identified by specialists and field work. Following the

recommendations from the scoping phase, the development footprint for the Clayville Thermal Plant was

confirmed. The specialist assessments undertaken within this EIA phase have considered the 1.76ha

project site as well as the project development footprint (refer to Figure 6.1).

The development of the Thermal Plant will comprise the following phases:

» Pre-Construction and Construction – will include pre-construction surveys; site preparation;

establishment of ancillary infrastructure such as access roads, guard house, admin building, workshops,

warehouse and transportation of components/construction equipment to site. The construction phase

for the Thermal Plant is expected to take approximately 36 months.

» Operation – will include the operation of the Clayville Thermal Plant and the generation of steam

which will be provided to several off-takers located within the Clayville industrial area. The operation

phase of the project is expected to be more than 35 years.

» Decommissioning – depending on the economic viability of the Thermal Plant, the length of the

operation phase may be extended beyond a 35 year period. Decommissioning activities will involve

disassembly of the production units and ancillary infrastructure, demolishing of buildings and

rehabilitation to the desired end-use. As far as possible components will be broken down and

recycled. Note that impacts associated with decommissioning are expected to be similar to those

associated with construction activities.

Clayville Thermal Plant in the Clayville Industrial Area, Gauteng Province



Figure 6.1: Map showing the layout for the Clayville Thermal Plant and associated infrastructure located within Erf 457, Erf 459 and Portion 12

of Erf 508 (refer to Appendix J for A3 maps).




6.1 Legal Requirements as per the EIA Regulations for the undertaking of a Environmental Impact

Assessment (EIA) Report, 2014 (as amended)

This chapter of this final EIA report includes the following information required in terms of Appendix 3:



(h)(v) the impacts and risks identified including the

nature, significance, consequence, extent, duration and

probability of such identified impacts, including the

degree to which these impacts (aa) can be reversed

(bb) may cause irreplaceable loss of resources and (cc)

can be avoided, managed or mitigated.

The potential impacts associated with the construction

and operation of the Clayville Thermal Plant are

identified and evaluated within section 6.2 to section 6.5.

Further detail is provided in the specialist studies

contained in Appendix D – F.

(h)(vii) positive and negative impacts that the proposed

activity and alternatives will have on the environment

and on the community that may be affected focusing

on the geographical, physical, biological, social,

economic, heritage and cultural aspects

The positive and negative impacts associated with the

development of the Clayville Thermal Plant are

summarised in section 6.2 to section 6.5. Further detail is

provided in the specialist studies contained in Appendix

D – F.

(h)(viii) the possible mitigation measures that could be

applied and level of residual risk

Recommendations regarding the development of the

Thermal Plant are included in section 6.2 and section 6.5.

Further detail is provided in the specialist studies

contained in Appendix D – F.

(i) a full description of the process undertaken to identify,

assess and rank the impacts the activity and associated

structures and infrastructure will impose on the preferred

development footprint on the approved site as

contemplated in the accepted Scoping Report through

the life of the activity, including (i) a description of all

environmental issues and risks that were identified during

the environmental impact assessment process, (ii) an

assessment of the significance of each issue and risk and

an indication of the extent to which the issue and risk

could be avoided or addressed by the adoption of

mitigation measures.

A description of the environmental issues and risks that

were identified during the environmental impact

assessment process and an assessment of the

significance of each issue and risk and an indication of

the extent to which the issue and risk could be avoided

or addressed by the adoption of mitigation measures are

included in sections 6.2.2, 6.2.3, 6.3.2, 6.3.3, 6.4.2, 6.4.3,

6.5.1 and 6.5.2.

(j) an assessment of each identified potentially significant

impact and risk, including (i) cumulative impacts, (ii) the

nature, extent, and consequences of the impact and

risk, (iii) the extent and duration of the impact and risk,

(iv) the probability of the impact and risk occurring, (v)

the degree to which the impact and risk can be

reversed, (vi) the degree to which the impact and risk

may cause irreplaceable loss of resources and (vii) the

degree to which the impact and risk can be mitigated.

An assessment of each potentially significant impact and

risk including the, the nature, extent, and consequences

of the impact and risk, the extent and duration of the

impact and risk, the probability of the impact and risk

occurring, the degree to which the impact and risk can

be reversed, the degree to which the impact and risk

may cause irreplaceable loss of resources and the

degree to which the impact and risk can be mitigated is

included in sections 6.2.3, 6.3.3, 6.4.3 and 6.5.2. A

separate cumulative assessment is included in Chapter 7.

(m) based on the assessment, and where applicable,

recommendations from the specialist reports, the

recording of proposed impact management outcomes

for the development for inclusion in the EMPr as well as

for inclusion as conditions for authorisation.

Recommendations from the specialists and mitigation

measures from the specialist reports for inclusion in the

EMPr are discussed within sections 6.2.3, 6.3.3, 6.4.3 and

6.5.2 and within the EMPr, which is included as Appendix

H. The EMPr also includes the recording of the





management objective and the impact management

outcomes.

6.2. Potential Impacts on Ambient Air Quality

Potential impacts on the ambient air quality and associated risks to human health, and the relative

significance of the impacts associated with the development and operation of the Clayville Thermal Plant

are summarised below (refer to Appendix D – Air Quality Impact Assessment Report for more details).

In the Clayville Industrial Area air pollution sources include industrial activity and motor vehicle emissions.

Fuel burning in nearby residential areas may also influence air quality. Several sensitive receptors have

been identified within close proximity to the project site and include:

» Clayville East (~1km east of the project site);

» Tswelapele (~1km west of the project site);

» Tembisa Provincial Hospital (~1.3km south of the project site);

» Clayville (~1.5 km north of the project site); and

» Olifantsfontein residential (~1.5 km south east of the project site).

These are areas where the occupants are more susceptible to the adverse effects of exposure to toxic

chemicals, pesticides and other pollutants.

6.2.1 Results of Impact Assessment

South Africa has established National Ambient Air Quality Standards (NAAQS) for criteria pollutants, i.e.

SO2, NO2, CO, PM10, PM2.5, ozone (O3), lead (Pb) and benzene (C6H6) (DEA, 2009 and, 2012). National dust

control regulations were published on 1 November 2013 (DEA, 2013b), setting limits for acceptable dustfall

rates for residential and non-residential areas.

The NAAQS consists of a ‘limit’ value and a permitted frequency of exceedance. The limit value is the

fixed concentration level aimed at reducing the harmful effects of a pollutant on human health. The

permitted frequency of exceedance represents the acceptable number of exceedances of the limit

value expressed as the 99th percentile. Compliance with the ambient standard implies that the frequency

of exceedance of the limit value does not exceed the permitted tolerance. Being a health-based

standard, ambient concentrations below the standard imply that air quality poses an acceptable risk to

human health, while exposure to ambient concentrations above the standard implies that there is an

unacceptable risk to human health.

To assess the impact of emissions from the proposed Clayville Thermal Plant on ambient air quality and

human health, a dispersion modelling study was undertaken to predict ambient concentrations of

pollutants resulting from the emissions.

Three scenarios were modelled for the Clayville Thermal Plant in order to predict the potential operation

impacts. These include

» Coal-fines only Scenario;

» Syngas only Scenario; and

» Natural gas only Scenario.




The predicted ambient concentrations are assessed against the NAAQS for PM10, SO2, NOX and CO.

i. Sulphur Dioxide (SO2)

The source of SO2 from the proposed Clayville Thermal Plant includes the CFB boiler stack. The current

ambient SO2 concentrations in Olifantsfontein are relatively low compared with the NAAQS. The

implication is that the SO2 emissions from the proposed Clayville Thermal Plant will have a marginal

additive effect on existing ambient concentrations and they are highly likely to remain considerably below

the NAAQS of 50 µg/m3, for the coal fines-only option. For Syngas and natural gas, SO2 concentrations are

very low. No exceedance of the NAAQS is predicted within the proposed project site or in any residential

and sensitive receptor areas surrounding the project site.

ii. Nitrogen Dioxide (NO2)

The source of NO2 from the proposed Clayville Thermal Plant includes the CFB boiler stack. The current

ambient NO2 concentrations in Olifantsfontein are relatively high compared with the NAAQS and are

attributed mostly to motor vehicle emissions. The predicted ambient NO2 concentrations resulting from

emissions from the proposed Clayville Thermal Plant are highest for the coal fines-only option but are very

low overall and will have a marginal additive effect on existing ambient concentrations. There will

therefore be some additive effect to the existing NO2 concentrations. For the Syngas and natural gas

options, NO2 concentrations are very low. No exceedance of the NAAQS is predicted within the proposed

project site or in any residential and sensitive receptor areas surrounding the project site.

iii. Carbon Monoxide (CO)

The source of CO from the proposed Clayville Thermal Plant includes the CFB stack. The predicted

ambient CO concentrations are well below the NAAQS of 10 000 µg/m3; and no exceedance of the

NAAQS is predicted within the project site or in any residential and sensitive receptor areas around the site.

The predicted CO concentrations therefore comply with the NAAQS in the ambient environment.

iv. Particulate Matter PM10

The main source of PM10 from the proposed Clayville Thermal Plant is the CFB boiler stack. The predicted

PM10 concentrations resulting from the Clayville Thermal Plant emissions are very low for the coal fines - only

scenario. The additive effect for this scenario will be marginal. For the Syngas and natural gas options, the

concentration of PM10 is negligible. The predicted ambient concentrations are well below the NAAQS of

40 µg/m3; and no exceedance of the NAAQS is predicted within the proposed Clayville Thermal Plant site

or in any residential and sensitive receptor areas surrounding the project site.

6.2.2 Description of Impacts

The effects of air pollutants on human health occur in several ways with short-term, or acute effects, and

chronic, or long-term, effects. Different groups of people are affected differently, depending on their level

of sensitivity, with the elderly and young children being more susceptible. Factors that link the

concentration of an air pollutant to an observed health effect are the concentration and the duration of

the exposure to that particular air pollutant.




The key issues associated with the construction, operation and decommissioning phases of the Clayville

Thermal Plant include:

Construction and decommissioning phase:

Construction work will entail building of new infrastructure and heavy construction work with concrete,

steel, piping, etc. Dust emissions during construction result mainly from earth moving activities (scraping,

compacting, excavation, grading), movement of construction vehicles and back-fill operations. Dust

emissions during decommissioning result from the demolition of structures, earth moving activities (scraping,

compacting, excavation, grading), movement of construction vehicles and back-fill operations.

All aspects of the construction and decommissioning inherently generate dust, but the movement of

construction vehicles on paved and unpaved surfaces at the construction site are generally the largest

source of dust. Construction vehicles will be in operation for the duration of the construction and

decommissioning. Dust is also easily entrained from exposed areas by the wind.

The impact of dust is considered to be more of a nuisance nature and does not typically pose a health risk

due to its typically coarse size. The impact of dust from the construction and decommissioning activities on

air quality is relatively short lived, i.e. limited to the duration of the construction or decommissioning

activities. The impacts are also expected to be localised and limited to the area adjacent to the activity.

Operation phase:

For the coal fines-only scenario, the ambient SO2, NO2, CO and PM10 concentrations resulting from the CFB

boiler stack emissions are predicted to be significantly below the NAAQS and no exceedances of the

respective standards are predicted. The significance of the impact on ambient air quality and human

health for the coal fines-only scenario is considered to be low.

For the Syngas and natural gas scenarios, the ambient SO2, NO2 and CO concentrations resulting from the

CFB boiler stack emissions are predicted to be significantly lower than the coal fines-only scenario and are

therefore well below the NAAQS and no exceedances of the respective standards are predicted. The

significance of the impact on ambient air quality and human health for the Syngas and natural gas

scenarios are considered to be low.

Several of the potential off-takers within the Clayville industrial area already make use of coal-fired boilers

on their site to produce steam to use in various direct and indirect processes within their plants. Other fuel

sources used by off-takers include diesel, HFO and gas. The installation of the Clayville Thermal Plant will

eliminate the need for small boilers on the off-taker’s sites and will therefore reduce different emission

sources from the various boilers within the area. This is considered to be a benefit in terms of air quality in

the area.

6.2.3 Impact table summarising the significance of impacts on the ambient air quality during

construction and operation (with and without mitigation)

Construction/Decommissioning Phase Impacts

Impact on ambient air quality and human health

Nature:

The impact of dust generated from construction and decommissioning activities do not typically pose health risks. It is

rather a nuisance impact due the typically coarse particle size. Due to relatively short duration of the activities, the

impact on ambient air quality and health is expected to be localised and limited to the construction or




decommissioning period.

Without mitigation With mitigation

Extent Local (2) Site specific (1)

Duration Short term (1) Short term (1)

Magnitude Low (4) Low (4)

Probability Probable (3) Improbable (2)

Significance Low (21) Low (12)

Status (positive or negative) Negative Negative

Reversibility Low High

Irreplaceable loss of resources? No No

Can impacts be mitigated? Yes Yes

Mitigation:

» A dust management programme should be implemented during the construction and decommissioning phases of

the project. The programme should include dust control during construction and decommissioning such as

implementing appropriate dust suppression on unpaved site roads and open areas, sweeping paved areas, and

speed enforcement on-site.

Residual Risks:

The residual risk is of low significance, reversible with no loss of resources.

Operation Phase Impacts

The coal-fines only Scenario is considered to be the worst-case scenario and therefore any combination of

fuel sources which reduces the reliance on coal fines would result in emissions lower than those predicted

for the coal-fines only Scenario, resulting in a lower impact.

Impact on ambient air quality and human health

Nature:

The impact of emissions from the CFB boiler will increase ambient concentrations of PM10, SO2, NO2 and CO which

pose risk to human health.


Coal Fines Scenario Syngas Scenario Natural Gas Scenario All Scenarios

Extent Local (2) Local (2) Local (2) Local (2)

Duration Long term (4) Long term (4) Long term (4) Long term (4)

Magnitude Low (4) Minor to Low (3) Minor to Low (3) Minor to Low (3)

Probability Probable (3) Improbable (2) Improbable (2) Improbable (2)

Significance Medium (30) Low (18) Low (18) Low (18)

Status (positive

or negative)

Negative Negative Negative Negative

Reversibility Low Low Low High

Irreplaceable

loss of

resources?

No No No No

Can impacts

be mitigated?

Yes

Mitigation:

» The installation and operation of an Electrostatic Precipitator (ESP) for particulate reductions;

» The use of sorbent for SO2 reduction;




» The progressive move from initially using coal fines to using clean fuels such as Syngas and natural gas.

» Maintenance of emission abatement devices according to design specifications.

Residual Risks:

The residual risk after the implementation of mitigation measures will be of low significance for the coal fines-only

scenario and lower for the gas scenarios with no loss of resources. rainfall

6.2.4 Implications for Project Implementation

The operation of the Clayville Thermal Plant will generate low emissions which will result in low ambient SO2,

NO2, CO and PM10 concentrations, and low ambient air quality impacts for the construction, operation

and decommissioning phases. The proposed development and associated infrastructure is unlikely to

result in permanent damage to ambient air quality, and poses a low risk to human health. With the

implementation of mitigation measures by the developer, contractors, and operational staff, the severity

of negative impacts can be mitigated to low significance, or avoided. The Clayville Thermal Plant can be

developed and impacts on air quality managed by taking the following into consideration:

» The installation and operation of an Electrostatic Precipitator (ESP) for the reduction of particulates.

» The use of sorbent for the reduction of SO2 emissions.

» The progressive move from initially using coal fines to using clean fuels such as Syngas and natural gas.

6.3. Potential Impacts on Heritage Features

The project site of 1.76ha has been assessed for the development of the Thermal Plant. Negative impacts

on heritage resources will be as a result of loss during construction activities. Potential impacts and the

relative significance of the impacts are summarised below (refer to Appendix E).


The eastern section of the project site is occupied by Civcon Engineering Works and other businesses (refer

to Figure 6.2). These businesses occupy several buildings, workshops and storerooms. The remaining

section of the project site is vacant land. The site is considered to be largely disturbed by the

development of numerous modern buildings and infrastructure. No standing structures older than 60 years

were identified within the project site.

Figure 6.2: Built-up areas and existing buildings within the project site.




The general area under investigation has a wealth of heritage sites and a cultural layering including LSA

scatters and numerous grave sites and cemeteries. No Stone Age or Iron Age artefacts, burial sites or

battlefield sites were identified within the project site. The cultural landscape of the greater area is

characterised by industrial developments and the project will not impact on significant viewscapes.


The pre-construction phase involves the removal of topsoil and vegetation (applicable to Erf 457 and

Portion 12 of Erf 508) as well as the establishment of infrastructure needed for the construction phase.

These activities can have a negative and irreversible impact on heritage sites. Impacts include destruction

or partial destruction of non-renewable heritage resources. During the construction phase, the impacts

and effects are similar in nature but more extensive than the pre-construction phase. These activities can

have a negative and irreversible impact on heritage sites and include the destruction or partial destruction

of non-renewable heritage resources.

No heritage features of significance were identified within the project site. The impact on heritage sites by

the development of the Clayville Thermal Plant and associated infrastructure is therefore considered to be

low. Any direct impacts that may occur would be during the construction phase only and would be of

very low significance.

6.3.3 Impact table summarising the significance of heritage impacts (with and without mitigation)

Impact on archaeological heritage resources:

Nature:

During the construction phase activities resulting in disturbance of surfaces and/or sub-surfaces may destroy, damage,

alter, or remove from its original position archaeological material or objects.


Extent Site specific (1) Site specific (1)

Duration Permanent (5) Permanent (5)

Magnitude Low (2) Low (2)

Probability Improbable (3) Improbable (3)



Reversibility Not reversible Not reversible

Irreplaceable loss of resources? No resources were recorded No resources were recorded

Can impacts be mitigated? Yes, a chance find

procedure should be

implemented.

Yes

Mitigation:

» A Chance Find Procedure should be implemented for the project site should any sites be identified during the

construction phase of the project.

Residual Risks:

If sites are destroyed, it will result in the depletion of archaeological record of the area. Should sites be recorded and

preserved or mitigated, it will add to the archaeological record of the area.





The significance of impacts on heritage sites due to the development of the Clayville Thermal Plant are

considered to be low with the implementation of mitigation measures by the developer, contractors, and

operational staff. From the outcomes of the Heritage Impact Assessment undertaken, it can be

concluded that the Thermal Plant can be developed and impacts on heritage resources managed with

the implementation of a Chance Find Procedure should any sites be identified during the construction

phase of the project. No other mitigation will be required.

6.4. Potential Impacts on Traffic

Access to the project site will be via existing roads – i.e. Spanner Road adjacent to the western boundary

of the project site and Industrial Road adjacent to the eastern boundary of the project site. The impact of

the proposed development on traffic from a national, regional and local perspective has been assessed

as of medium significance. Potential impacts and the relative significance of the impacts are summarised

below (refer to Appendix F – Traffic Impact Assessment Report for more details).


The following characteristics were assessed as part of the Traffic Impact Assessment for the Clayville

Thermal Plant:

» Visual assessment of the project at the proposed access to the site taking into consideration the road

network and accessibility, road surface, the line markings of the road and the sight distance at the

access point.

» Accessibility to the site includes two-lane arterial roads characterised by signalised intersections that

provide access links to the industrial area as below:

The R562 which forms an important road link between the N1 to the west of Clayville industrial

area and the R21 to the east of Clayville Industrial Area.

The M18 which is considered to be a north-south orientated route, with mostly industrial related

traffic in the vicinity of the Clayville industrial area and lighter traffic volumes north of S View

Road. The M18 also provides access to the R562 to the south and to Nellmapius Drive to the

north of Clayville industrial area.

S View Road is a connector link between the R562 and Hoof Road. A high percentage of

traffic on this road link is generated by Clayville Industrial Area.

The road network in the vicinity of the project site is typical to many of the industrial developments,

comprising 8m wide two-lane roads centrally located in 25m wide road reserves. These roads are

characterised by a high number of site accesses, unkept road verges and a lack of pedestrian facilities,

apart from Nut Avenue that provides a paved sidewalk for pedestrians (along the northern road edge).

The road surfaces are premixed and are generally in a good condition. Some faded road markings are

evident in areas and should be addressed with regular maintenance. The road network in close proximity

to the proposed project site is described below:

» Access to the project site is attained via Spanner and Industry Roads. These north-south orientated

roads intersect with S View Road, some 1,0 km to the north of the project site.

» Nut Avenue and Nail Avenue provides east-west orientated links between Spanner and Industry Roads.




The transportation routes to the site includes the R42, R50, R25, M57 and R562. Apart from the M57 (a

metropolitan route) the major portion of the route is along Regional (R) Routes. These Regional and

Metropolitan Routes carry mixed traffic and can readily accommodate the traffic impact of the Thermal

Plant.

Traffic counts on the Industry Road/Nut Avenue intersection at the weekday AM and PM peak periods

indicated that there is a fairly high traffic volume and that the traffic volume exceeds the capacity of a

four-way Stop controlled intersection. Traffic counts on the Industry Road/Nail Avenue intersection (three-

way Stop) at indicated low traffic volumes and can more readily accommodate the traffic impact of the

project.


Impacts on traffic will be most significant during the construction phase of the Thermal Plant due to an

increase of heavy vehicles on the regional and local road network of the area. However, based on the

expected traffic to be generated by the project, it is considered that the Clayville Thermal Plant

construction, operation and decommissioning traffic volumes are not significant and can be

accommodated on the affected road network with ease. The four-way stop controlled intersection of

Industry Road / Nut Avenue is however already over capacity and it is recommended that the intersection

be signalised. Therefore, it can be concluded that the development of the Clayville Thermal Plant will not

have a detrimental impact on traffic aspects and is appropriate and suitable from a traffic perspective.

6.4.3 Impact table summarising the significance of traffic impacts (with and without mitigation)

The impacts assessed below apply to the development of the Clayville Thermal Plant within the Clayville

industrial area and the associated access roads.

Construction Phase Impacts

Road safety impacts relating to the construction phase of the Thermal Plant

Nature:

During the construction phase (36 months) some heavy and abnormal load vehicles will transport equipment,

machinery and structural elements to site from Johannesburg via the National road network. Heavy and light vehicles

trips will impact on Industry Road in particular. There will be a low increase in traffic volumes impacting on traffic

congestion and road safety.


Extent Local to Regional (3) Local to Regional (3)

Duration Short-term (2) Short-term (2)

Magnitude Minor to low (3) Minor (2)

Probability Definite (5) Definite (5)

Significance Medium (40) Medium (35)


Reversibility Reversible Reversible


Can impacts be mitigated? Yes, mitigation should enhance road safety.

Mitigation:

» All construction vehicles must be road worthy.




» All construction vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly

adhere to the rules of the road.

» Heavy vehicle and abnormal load vehicles should travel outside of commuter peaks where possible.

» Erect signage warning of construction vehicles at development access.

» Deploy flagmen at the access to enhance road safety when necessary where dealing with abnormal load

vehicles entering or leaving the project site.

Residual Risks:

Minor degradation of the national, metropolitan and regional road network.

Traffic impacts relating to intersection capacity during the construction phase of the Thermal Plant

Nature:

During the construction phase, Industry Road will carry the highest traffic flow to the project site. The intersection of

Industry Road / Nut Avenue is a four-way Stop controlled intersection which is already over capacity. Consequently,

any increase in traffic will have a more significant impact on vehicle delay at this intersection.


Extent Local (2) Local (2)


Magnitude Moderate (6) Minor (2)


Significance Medium (50) Medium (30)




Can impacts be mitigated? Yes, capacity improvements are already justified at Industry Road

/ Nut Avenue intersection and should be implemented to improve

the current situation, to the benefit of current road users and the

proposed development traffic as well.

Mitigation:

» Consult with the relevant authority regarding the upgrade of the Industry Road / Nut Avenue Multi-way stop

controlled intersection to a signalised intersection.

Residual Risks:

The traffic signals will attract Operating and Maintenance costs.

Operation Phase Impacts

Road safety impacts relating to the operation phase of the Thermal Plant

Nature:

During the operations phase, the affected road network leading to the project site will include trucks transporting coal

fines from Delmas and Middelburg Areas. There will be an insignificant increase in traffic volumes, including heavy

vehicles, contributing to overall traffic congestion and road safety.




Magnitude Minor (2) Minor (2)

Probability Definite (5) Highly probable (4)

Significance Medium (30) Low (24)







Can impacts be mitigated? Yes

Mitigation:

» All transport vehicles must be road worthy.

» All vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly adhere to the rules

of the road.

» Heavy vehicles should travel outside of commuter peaks where possible.

» Trucks to be covered and properly sealed to retain coal fines and prevent it from spilling and blowing into the

roadway during transportation.

» Obtain bulk of Coal Fines from the Delmas Area as opposed to from Middleburg Area.

» Construct a deceleration lane on Industry Road to accommodate left-turn vehicles entering the development, or

introduce a second entry lane at the site access on Industry Road.

» Create additional access to the site via Spanner Road, to improve on-site manoeuvrability, to reduce right-turn

exit movements at the development access and to reduce traffic impact on Industry Road.

Residual Risks:

Minor degradation of the affected road network.

Traffic impacts relating to intersection capacity during the operation phase

Nature:

During the operations phase, Industry Road will carry the highest development traffic flow as it leads directly to the

project site. Industry Road / Nut Avenue intersection is a four-way stop controlled intersection and is already over

capacity. Consequently, any increase in traffic will have a more significant impact on vehicle operating costs (fuel

and maintenance) and vehicle delay (time).




Magnitude Moderate (6) Minor (2)






Can impacts be mitigated? Yes, capacity improvements are already justified at Industry Road

/ Nut Avenue intersection and should be implemented to improve

the current situation, to the benefit of current road users and the

proposed development traffic as well.

Mitigation:

» Consult with the relevant authority regarding the upgrade of the Industry Road / Nut Avenue Multi-way stop

controlled intersection to a signalised intersection.

Residual Risks:

Operating and maintenance of traffic signals will be required.

Decommissioning Phase Impacts

Road safety impacts relating to the decommissioning phase of the Thermal Plant

Nature:

The road network surrounding the Thermal Plant will be affected. There will be an increase in traffic, impacting on

traffic congestion and road safety (light and heavy vehicles), however the extent of the impact will be of a local

nature. The traffic expected during the decommissioning phase will temporarily add an insignificant traffic volume to




the road network.



Duration Very short duration (1) Very short duration (1)


Probability Highly probable (4) Probable (3)





Can impacts be mitigated? Yes, mitigation should enhance road safety.

Mitigation:

» All construction vehicles must be road worthy.

» All construction vehicle drivers must have the relevant licenses of the use of the vehicles and need to strictly

adhere to the rules of the road.

» Heavy vehicles should travel outside of commuter peaks where possible.

Residual Risks:

Minor degradation of the regional and local road network of the surrounding area.


With the implementation of mitigation measures by the developer, contractors, and operational staff, the

severity of traffic impacts of the Thermal Plant can be reduced or avoided. The Thermal Plant can be

developed and impacts on traffic managed by taking the following into consideration:

» Road sign warning of construction vehicles at the development access should be erected on Industry

Road for the construction period.

» The development gate should be located at least 25m from the travelled way to accommodate

larger construction vehicles to and from the project site, and to accommodate access control during

the operational period.

» Abnormal Load Vehicles require Abnormal Load Permits to be obtained by the transport carrier.

» The developer should engage with the relevant authority regarding the installation of traffic signals at

the Industry Road/Nut Avenue intersection to improve the intersection performance.

» If possible, the applicant should obtain the bulk of coal fines from the Delmas Area as opposed to

from the Middleburg Area.

» The applicant should promote the use of public transport to workers during the operation phase.

6.5. Impacts related to the Storage and Handling of Dangerous Goods

During the operation phase, the Thermal Plant will require the storage of materials which may be

considered to be dangerous goods, including chemicals for the wastewater treatment plant and diesel.

"Dangerous goods" is defined under the Listing Notices that deal with the storage, or storage and handling,

of dangerous goods. "Dangerous goods" are defined in the Listing Notices as:

"Goods containing any of the substances as contemplated in South African National Standard No. 10234,

supplement 2008 1.00: designated “List of classification and labelling of chemicals in accordance with the

Globally Harmonized Systems (GHS)” published by Standards South Africa, and where the presence of




such goods, regardless of quantity, in a blend or mixture, causes such blend or mixture to have one or

more of the characteristics listed in the Hazard Statements in section 4.2.3, namely physical hazards, health

hazards or environmental hazards".

The above definition makes specific reference to SANS 10234. South Africa has implemented the Globally

Harmonized System of Classification and Labelling of Chemicals by issuing this national standard. The

dangerous goods likely to be stored or handled on site would mainly include chemicals and diesel.

6.5.1 Description of Impacts associated with the Storage and Handling of Dangerous Goods

The operation of the Clayville Thermal Plant requires the storage of dangerous goods, including chemicals

and fuels for everyday operation. Infrastructure for storage and handling of a dangerous good will be

located in containers and will not exceed 80m³ (cubic metres). These substances will be stored on-site in

appropriate storage vessels within bunded areas/ on impervious surfaces. The storage and handling of

dangerous goods has the potential to result in soil and/or water contamination should any

spillages/leakages occur. This is considered to be the most significant risk, other than a direct risk to

personnel on site, which is an occupational health and safety issue and is considered in line with the OH&S

Act. While not all materials to be stored on site are considered to be hazardous (or have a hazard rating),

materials such as fuel and oils are flammable and also have the potential to cause fires, explosions,

damage to infrastructure, as well as injuries of staff.

6.5.2 Impact table summarising the significance of the storage and handling of dangerous goods (with

and without mitigation)

Soil and water contamination as a result of spillages and/or leakages

Nature:

Soil and water contamination due to the handling and storage of dangerous goods during the operation phases.




Magnitude High (8) Low (4)

Probability Probable (3) Improbable (2)





Can impacts be mitigated? Yes Yes

Mitigation:

» Any spillages of dangerous substances must be contained as soon as possible, and remedial and clean-up actions

initiated immediately.

» Regular inspections of the permanent bunded areas for storage of dangerous goods must be undertaken

throughout the life cycle of the project.

» Appropriate spill kits must be available on site.

» Maintenance vehicles must have access to spill kits.

» An emergency spill response plan must be developed for implementation during the construction and the

operational phase. Personnel should be suitably trained to attend to any spills that may occur.

» A fire management plan must be developed for implementation during the construction and the operational

phase. Personnel must be suitably trained to manage any fires which may occur on site.




» Flammable substances must be stored in enclosed containers away from heat, sparks, open flames, or oxidizing

materials.

» Develop a monitoring and leak detection procedure for monitoring of the chemical spillages.

Residual Risks:

If spillages occur and are not cleaned up, contamination can result in impacts which remain after decommissioning of

the project.

6.6. Assessment of the Do Nothing Alternative

The ‘Do-Nothing’ alternative is the option of not constructing the proposed Clayville Thermal Plant. Should

this alternative be selected, there would be no environmental impacts on the site due to the construction

and operation activities of a Thermal Plant utilising CFB boiler technology. In addition, any benefits

associated with the development of the project will also not be realised.

Benefits of the project are expected to include:

» The implementation of the proposed project would utilise an existing waste by-product as a fuel source

to generate steam while reducing emissions within the Clayville industrial area. Coal fines are

considered to be an unwanted waste by‐product from the coal mining industry. These fines have

presented a major disposal challenge to the mining industry throughout South Africa and are currently

being stored as coal dumps and slurry dams, which emit CO2. South Africa produces approximately

300 million tons of coal per year of which up to 20% consist of coal fines. The Clayville Thermal Plant will

utilise 420 480 tonnes per year of this waste by-product as a feedstock for a CFB boiler to produce

steam, therefore providing an opportunity to convert a mining liability into a revenue stream. This is

considered to be a benefit from an environmental perspective as this would result in a reduction of the

amount of coal fines stored, and a subsequent reduction in CO2 emissions associated with this storage.

» Several of the potential off-takers within the Clayville industrial area already make use of coal-fired

boilers on their site to produce steam to use in various direct and indirect processes within their plants.

Other fuel sources used by off-takers include diesel, HFO and gas. The installation of the Clayville

Thermal Plant will eliminate the need for small boilers on the off-taker’s sites and will therefore reduce

different emission sources from the various boilers within the area. This is considered to be a benefit in

terms of air quality in the area.

» The project will result in socio-economic benefits at the local and regional scale through job creation,

procurement of materials and provision of services and other associated downstream economic

development. These will persist during the pre-construction, construction and operational phases of

the project.

» The project is considered to be a suitable land use for the proposed site due to the low potential for

commercial agriculture, the fact that the site is zoned for Industrial Use, the site is located within Zone 5

of the GPEMF which is the industrial and commercial development focus zone, and the proximity to an

existing coal fines and gas resources.

» The recycling of wastewater will result in a reduction of wastewater being disposed of to the municipal

system, thereby reducing the pressure on these systems and impacts on the environment.

» The development of Erf 457 and Erf 12 of 508 provides an opportunity to manage and control the alien

plant species currently present within the site. This would reduce the risk of such species spreading in

the surrounding areas.

The implementation of the project is expected to result in a number of environmental costs, as detailed

within this report, and would include:




» For the coal fines-only scenario an additive effect to the existing ambient concentrations is predicted

to be of low significance and negligible for the Syngas and natural gas options.

» Impacts on traffic are expected to occur and will be most significant during the construction phase of

the Thermal Plant due to an increase of heavy vehicles on the regional and local road network of

South Africa.

The benefits of the project are expected to occur at a regional and local level. The costs to the

environment occur at a site specific level and can largely be limited through the implementation of

mitigation measures. The no-go alternative will result in the above benefits not being realised and a

subsequent loss of income and opportunities to local people and the opportunity to lower emissions in the

Clayville industrial area. The no-go alternative for the development of the Thermal Plant is therefore not

considered as a desirable alternative.



Assessment of Cumulative Impacts Page 100

CHAPTER 7: ASSESSMENT OF CUMULATIVE IMPACTS

Cumulative impacts in relation to an activity are defined in the 2014 EIA Regulations (GNR 326) as meaning

“the past, current and reasonably foreseeable future impact of an activity, considered together with the

impact of activities associated with that activity, that in itself may not be significant, but may become

significant when added to the existing and reasonably foreseeable impacts eventuating from similar or

diverse activities.”

The Clayville Thermal Plant may have effects (positive and negative) on the social environment and on the

people living in the broader study area (i.e. Tswelapele and Clayville East). The Thermal Plant is proposed

to be located within the Clayville industrial area, approximately 4,3km south east of Olifantsfontein. The

project site and the greater Clayville industrial area has been identified as an industrial area and falls

within Zone 5 (Industrial and Commercial Development Focus Area) as described by the Gauteng

Provincial Environmental Management Framework, 2014. As the area is earmarked for the development

of industrial industries, it can be expected that various industrial developments will take place in addition

to the already industrial nature of the area. A concentration of industrial development within an area will

ultimately concentrate the impacts (both positive and negative) in one area where the development of

the industrial sector is deemed suitable as well as beneficial for the surrounding communities.

It is important to follow a precautionary approach in accordance with NEMA to ensure that the potential

for cumulative impacts are considered and avoided where possible, even if the cumulative impacts

expected are limited in extent and considered as being of a low significance. This chapter provides an

assessment of the cumulative impacts expected to be associated with the Clayville Thermal Plant when

considered together with other similar industrial developments in the area.



This chapter of the final EIA report includes the following information required in terms of Appendix 3:



3(j) an assessment of each identified potentially

significant impact and risk , including (i) cumulative

impacts, (ii) the nature, extent, and consequences of

the impact and risk, (iii) the extent and duration of the

impact and risk, (iv) the probability of the impact and

risk occurring, (v) the degree to which the impact and

risk can be reversed, (vi) the degree to which the

impact and risk may cause irreplaceable loss of

resources and (vii) the degree to which the impact and

risk can be mitigated.

This chapter focuses on the assessment of the

cumulative impacts associated with the Clayville

Thermal Plant as a whole.




7.2. Approach Taken to Assess Potential Cumulative Impacts

The cumulative impacts that have the potential to be compounded through the development of the

Clayville Thermal Plant and its associated infrastructure in proximity to other similar developments include

impacts such as those listed below. The role of the cumulative assessment is to test if such impacts are

relevant to the proposed project in the proposed location when considered together with other similar

developments. Potential impacts include:

» Unacceptable increase in emissions within the Clayville industrial area.

» Unacceptable risk to human health through impacts on air quality.

» Unacceptable impact on the traffic of the local area.

» Unacceptable loss of heritage resources.

The scale at which the cumulative impacts are assessed is important. For example the significance of the

cumulative impact on the regional or national economy will be influenced by similar developments

throughout South Africa, while the significance of the cumulative impact at a local scale will only be

influenced by industrial developments that are in close proximity to each other, i.e. industrial

developments within the Clayville industrial area in this instance.

The potential for cumulative impacts are summarised in the sections which follow and have been

considered within the detailed specialist studies, where applicable (refer to Appendices D – F).

The cumulative effects or impacts consider:

» Cumulative impacts associated with the location and nature of the project, i.e. a thermal plant

located within the Clayville industrial area on Erf 457, Erf 459 and Portion 12 of Erf 508;

» Cumulative impacts associated with other relevant approved or existing and proposed developments

within the surrounding area of the proposed Clayville Thermal Plant project site (refer to Figure 7.1).

The cumulative impacts of other known developments in the broader area and the Clayville Thermal Plant

are therefore qualitatively assessed in this Chapter. As these cumulative impacts are explored in more

detail, the trade-offs between promoting growth within the industrial sector versus the local and regional

environmental and social impacts and benefits can be considered.

The potential for cumulative impacts that could occur due to the development of the Thermal Plant in

proximity to other existing and proposed developments include impacts such as:

» Impacts on Air Quality and human health;

» Impacts on Archaeology and Heritage;

» Traffic Impacts.

In the sections below the potential cumulative impacts of other similar developments within the region are

assessed (proposed and operational). The discussion and associated conclusions must be understood in

the context of the uncertainty associated with the proposed development and the qualitative nature of

the assessment.




Figure 7.1: Other relevant existing developments within the surrounding area of the Clayville Thermal Plant project site (refer to Appendix J for A3 Map).




7.3. Cumulative Impacts Associated with the Development of the Clayville Thermal Plant

In the sections below the potential cumulative impacts of the Clayville Thermal Plant and other

developments are explored.

7.3.1. Potential Cumulative Impacts on Air Quality

The cumulative assessment aims to assess the additive effect of emissions from the proposed Clayville

Thermal Plant on existing ambient air quality in the area. For operations, the cumulative assessment utilised

the modelled (predicted) ambient concentrations for the Clayville Thermal Plant together with the

measured ambient concentrations of SO2, NO2 and PM10 at the Olifantsfontein and Tembisa monitoring

stations. In the absence of other measurements, the monitoring data at these two stations are deemed to

be representative of the assessment area.

v. Sulphur Dioxide (SO2)

The maximum predicted annual average SO2 concentration resulting from emissions from the proposed

Clayville Thermal Plant varies from 0.81 µg/m3 for S content of 1% to 1.62 µg/m3 for S content of 2% for the

coal fines-only scenario. The predicted SO2 concentrations will be negligible for Syngas and natural gas.

The measured ambient SO2 concentrations are relatively low and typically less than 20% of the annual

NAAQS. The SO2 emissions from the Clayville Thermal Plant will add only marginally to the existing ambient

concentrations in the area, and exceedances of the NAAQS are highly unlikely. As clean fuels are

introduced during the operation of the project (i.e. Syngas and natural gas), the impacts of SO2 will

decrease along with the additive effect.

vi. Nitrogen Dioxide (NO2)

The maximum predicted annual average NO2 concentration resulting from emissions from the proposed

Clayville Thermal Plant for the coal fines-only scenario is 0.77 µg/m3, and significantly less for Syngas and

natural gas. In residential areas surrounding the Clayville industrial area the predicted ambient

concentrations are very low relative to the NAAQS. Ambient monitoring at Olifantsfontein indicates

relatively high NO2 concentrations with exceedances of the NAAQS. The monitoring site is located

relatively close to major roads and the ambient concentrations can be attributed mostly to motor vehicle

emissions. At the Olifantsfontein monitoring station the NOX emissions from the Clayville Thermal Plant will

add less than 0.1 µg/m3 to the existing concentrations. At this monitoring site it is likely that exceedances

will continue to occur because of vehicle emissions. In residential areas the added effect due to the

Clayville Thermal Plant will be marginal and exceedances of the NAAQS are highly unlikely.

vii. Particulate Matter PM10

The maximum predicted annual average PM10 concentration resulting from emissions from the proposed

Clayville Thermal Plant for the coal fines-only scenario is very low. In the surrounding residential areas, the

predicted annual average concentrations are less than 0.1 µg/m3. Ambient PM10 is measured in Tembisa

where concentrations are high and exceed the NAAQS. This is mostly attributed to domestic fuel burning.

PM10 emissions from the proposed Clayville Thermal Plant will initially have a marginal additive effect on

existing concentrations. The effect will become negligible as clean fuels are introduced (i.e. Syngas and




natural gas). Exceedances will continue to occur in Tembisa (and other areas because of domestic fuel

burning) regardless of initial emission of PM10 from the proposed Clayville Thermal Plant.

The risk associated with the Clayville Thermal Plant from an air quality and human health risk perspective is

therefore considered to be low and acceptable.

Nature:

Cumulatively impact is considered to be negative as a result of the increase in ambient concentrations of SO2, NO2

and PM10) due to the project related activities during operation. Elevated ambient concentrations of fine particulates

will likely result in negative human health impacts.

Overall impact of the proposed

project considered in isolation

Cumulative Impact of the project and

other projects in the area

Extent Local (1) Low (2)

Duration Long-term (4) Long-term (4)

Magnitude Minor (2) Minor to Low (3)

Probability Probable (3) Probable (3)


Status Negative Negative

Reversibility High Low


Can impacts be mitigated? Yes N/A

Confidence in findings: High

Mitigation:

ESP for particulates and sorbent injection for SO2 with devices operated and maintained within specification.

Several of the potential off-takers within the Clayville industrial area make use of small boilers on their site to

produce steam to use in various direct and indirect processes within their plants. Fuel sources used by off-

takers include coal, diesel, HFO and gas. The installation of the Clayville Thermal Plant will eliminate the

need for small boilers on the off-taker’s sites and could lead to the decommissioning of these boilers. This

will therefore reduce different emission sources from the various boilers within the area and concentrate it

to one source. This is considered to be a benefit in terms of air quality in the area.

7.3.2. Potential Cumulative Impacts on Archaeology and Heritage

In general, cumulative impacts on heritage resources (i.e. archaeology) are relatively insignificant in this

area as heritage resources are sparsely distributed.

From an archaeological perspective the impact of the development on the heritage landscape and sites

is considered as being of a low significance. No archaeological sites, burial sites, battlefield sites or

significant cultural landscapes or viewscapes were identified to be associated with the development of

the Clayville Thermal Plant. Due to the absence of significant heritage features in the project site and

broader area the development of the Thermal Plant does not present a risk to unacceptable loss of

heritage resources. Therefore, the contribution of the proposed project to the cumulative impact is

expected to be negligible. However, it must be considered that as developments take place within the

area the impact on the heritage landscape and sites of low heritage significance is increased as the sites

are potentially destroyed by the associated construction activities. It still remains important for

development within the area to observe mitigation measures such as a Chance Find Procedure, and to




protect any sensitive heritage features where possible. Through the implementation of appropriate

mitigation measures for the Clayville Thermal Plant and other developments the cumulative impacts on

archaeological resources within the area can be considered as acceptable, without any unacceptable

loss or risks.

Nature:

The development of the project and other industrial developments within the industrial area may result in disturbance

of surfaces and/or sub-surfaces may destroy, damage, alter, or remove from its original position archaeological

material or objects.








Probability Very Improbable (1) Very Improbable (1)





Can impacts be mitigated? Yes Unknown


Mitigation:

A Chance Find Procedure should be implemented should any sites be identified.

7.3.3. Potential Cumulative Impacts on Traffic

The project site is situated within the Clayville industrial area which is earmarked for industrial use. It can be

expected that various industrial developments will take place in addition to the already industrial nature of

the area. Considering that the industrial area is an already extensively developed area, the road network

in the industrial area should, by design, be able to accommodate the increase in traffic due to the

expected increase in industrial development of the area.

Cumulative traffic impacts associated with the development of the Clayville Thermal Plant in relation to

future industrial developments is considered acceptable, without an unacceptable increase in impact.

Although the impact of the project in isolation is considered to be of low significance, the cumulative

impact of the project and other projects in the area will be of a medium significance. The industrial area

will require incremental and periodic upgrading of the metropolitan road network (links and intersections),

which is normal to development. It should however be noted that the Industry Road/Nut Avenue multi-

way Stop controlled intersection is already over capacity during peak periods and will require upgrading

(i.e. traffic signals).

Nature:

The road network surrounding the Clayville Thermal Plant will be slightly affected. There will be an increase in traffic

impacting on traffic congestion and road safety (light and heavy vehicles), however the extent of the impact will be

more of a local nature (where development traffic converges on Industry Road). The cumulative traffic impact of this

and future development of the surrounding industrial area will require incremental and periodic upgrading of the

metropolitan road network (links and intersections), which is normal to development.










Magnitude Minor (2) Minor to low (3)

Probability Probable (3) Highly probable (4)

Significance Low (24) Medium (36)




Can impacts be mitigated? Yes Unknown


Mitigation:

» Encourage public transport patronage (employers can incentivise workers to travel by public transport by

subsidising public transport trips). Ideally the Local Authority should provide an attractive public transport service to

lure motorists out of their private vehicles and into public transport.

» Obtain bulk of Coal Fines from the Delmas Area as opposed to from the Middleburg Area.

7.4. Conclusions Regarding Cumulative Impacts

Cumulative impacts and benefits on various environmental receptors will occur to varying degrees with

the development of the industrial sector and other developments within South Africa. The degree of

significance of these cumulative impacts is difficult to predict without detailed studies based on more

comprehensive data/information on each of the receptors and the site specific developments. The

current study assesses the cumulative impacts associated with the Clayville Thermal Plant together with

other industrial developments within the area on the basis of current and best available information, with

precautionary assumptions taken into account.

The development of the Clayville Thermal Plant is considered as acceptable and without any

unacceptable loss or risk to the environmental and social aspects of the project site and the broader area.

The risk associated with the Clayville Thermal Plant from an air quality and human health risk perspective is

also considered to be of low significance.

As the project site is located within an industrial area and within Zone 5 (Industrial and Commercial

Development Focus Area) as described by the Gauteng Provincial Environmental Management

Framework 2014, it can be expected that various developments within this area will be taking place in

future as the area was identified as being suitable for these types of developments.

Considering the findings of the specialist assessments undertaken for the project, the cumulative impacts

for the Clayville Thermal Plant will be acceptable, without any unacceptable loss or risks and the majority

are rated as being of low significance.

Table 7.1 provides a summary of the expected cumulative impacts associated with the proposed Clayville

Thermal Plant on the identified project site.




Table 7.1: Summary of the cumulative impact significance for the Clayville Thermal Plant

Specialist assessment Cumulative Impact Significance

(proposed project in isolation)

Cumulative Impact Significance

(proposed project and other

projects)

Air Quality Low Low

Archaeology Low Low

Traffic Low Medium

The role of the cumulative assessment is to test if such impacts are relevant to the Clayville Thermal Plant in

the proposed location. Considering the cumulative assessments undertaken for air quality, archaeology

and traffic, it can be concluded that the development of the Clayville Thermal Plant and other proposed

developments in the region are acceptable and will not result in an unacceptable loss or risk or an

increase of the impacts. The following can be concluded considering the Thermal Plant:

» The construction and operation of the proposed project will not result in an unacceptable risk to

human health through impacts on air quality, as is evidenced by the absence of exceedances of the

NAAQS for the various pollutants under consideration. The anticipated cumulative impacts of the

proposed project are therefore considered to be within acceptable limits from an air quality

perspective.

» The construction and operation of the proposed project will not result in an unacceptable loss of

archaeological or heritage resources, largely due to the absence of such sites within the development

area. The anticipated cumulative impacts of the proposed project are therefore considered to be

within acceptable limits from an archaeological and heritage perspective.

» The construction and operation of the proposed project will not result in an unacceptable impact on

the traffic of the local area, largely as a result of the location of the development site within an

industrial area. The Clayville Thermal Plant is considered acceptable when considering the potential

for impacts to traffic, and will not significantly impact on the national and regional road network of

South Africa and the areas surrounding the project site.

Based on a detailed evaluation, the cumulative impacts associated with the construction and operation

of the Clayville Thermal Plant and other developments in the region are considered to be acceptable.

The low potential for cumulative impacts and risks makes the location of this project site a desirable

location for further consideration provided that environmental impacts are mitigated to suitable standards

by strict control and implementation of the EMPr, as recommended within this final EIA Report.



Conclusions and Recommendations Page 108

CHAPTER 8 CONCLUSIONS AND RECOMMENDATIONS




within the Ekurhuleni Metropolitan Municipality. The proposed project is to be known as the Clayville

Thermal Plant and the development footprint of the facility will be appropriately placed within the project

site of approximately 1.76ha in extent.

The purpose of the central plant would be to provide steam to off-takers in the industrial area, thereby

eliminating the need for each of the off-takers to produce their own steam for use in various processes on

their various sites (including industrial production, power generation, etc.). It is proposed to utilise coal fines

in combination with syngas and/or natural gas as feedstock for the CFB boiler. The steam generation plant

will have a capacity of up to 240 tons of steam per hour which is an equivalent of up to 60 MWe.

The development of the thermal plant in the Clayville industrial area will provide the opportunity to utilise

an already available resource such as coal fines which are regarded as a waste by-product from coal

mining, as a fuel to produce steam for off-takers to utilise in various processes (i.e. direct heat, process

steam, power generation etc.). Potential steam off-takers include Aspen, Astral Foods, Clover SA, Sasko

Nestle R&R Ice cream, Norcros Johnson and Vesuvius.

Steam generated at the central plant will also be utilised to generate power via steam turbines. These

turbines will be owned by the various off-takers, and each turbine will be sized to each off-taker’s

requirements. Should the electricity output of an individual turbine exceed 10MW, an environmental

authorisation will be required to be obtained.

The conclusions and recommendations of this EIA are the result of the assessment of identified impacts by

a team of independent specialist consultants, and the parallel process of Public Participation. The Public

Participation process has been extensive and every effort has been made to include representatives of all

stakeholders in the broader study area. A summary of the recommendations and conclusions for the

Clayville Thermal Plant is provided in this Chapter.



This chapter of the final EIA report includes the following information required in terms of Appendix 3:



(k) where applicable, a summary of the findings and

recommendations of any specialist report complying

with Appendix 6 to these Regulations and an indication

as to how these findings and recommendations have

been included in the final assessment report.

A summary of the findings of the specialist reports are

included within section 8.4. The recommendations

made by the specialists are included in Chapter 6. A

summary of the recommendations for the Thermal Plant

is included in section 8.8.

(h)(x) a concluding statement indicating the location of

the preferred alternative development footprint within

No preferred alternative development locations within

the preferred project site have been identified for the





the approved site as contemplated in the accepted

Scoping Report.

Clayville Thermal Plant due to the lack of environmental

sensitivities within the site. The reasoning behind the

exclusion is included in section 8.4.

(l) an environmental impact statement which contains

(i) a summary of the key findings of the environmental

impact assessment, (ii) a map at an appropriate scale

which superimposes the proposed activity and its

associated structures and infrastructure on the

environmental sensitivities of the preferred site indicating

any areas that should be avoided, including buffers and

(iii) a summary of the positive and negative impacts and

risks of the proposed activity and identified alternatives.

An environmental impact statement (overall conclusion)

is included in section 8.7. A summary of the key findings

of the environmental impact assessment is included in

sections 8.4.1 – 8.4.4. A map superimposing the

proposed activities and its associated infrastructure on

the environmental sensitivities of the preferred

development area indicating sensitive receptors in close

proximity to the project site are included Figure 8.1. No

environmental sensitivities have been identified within

the project site. A summary of the costs (negative) and

benefits (positive) impacts and risks of the proposed

Clayville Thermal Plant is included in section 8.6.

(n) the final proposed alternatives which respond to the

impact management measures, avoidance and

mitigation measures identified through the assessment.

The final proposed alternatives for the Clayville Thermal

Plant which responds to the impact management

measures, avoidance and mitigation are included in

section 8.8.

(o) any aspects which were conditional to the findings

of the assessment either by the EAP or specialist which

are to be included as conditions of authorisation.

Conditions to be included in the authorisation of the

Clayville Thermal Plant are included in section 8.8.

(q) a reasoned opinion as to whether the proposed

activity should or should not be authorised, and if the

opinion is that it should be authorised, any conditions

that should be made in respect of that authorisation.

A reasoned opinion as to whether the Clayville Thermal

Plant should receive authorisation and the conditions

that should form part of the authorisation is included in

section 8.8.

8.2 Assessment Process

An Environmental Impact Assessment process, as defined in the NEMA EIA Regulations, is a systematic

process of identifying, assessing, and reporting environmental impacts associated with an activity. The EIA

process forms part of the planning of a project and informs the final design of a development. In terms of

the EIA Regulations published in terms of Section 24(5) of the National Environmental Management Act

(NEMA, Act No. 107 of 1998), Bellmall Energy Project 325 (Pty) Ltd requires authorisation from the Gauteng

Department of Agriculture and Rural Development (GDARD) for the installation of the Clayville Thermal

Plant.

The EIA process for the Clayville Thermal Plant has been undertaken in accordance with the EIA

Regulations of 2014 as amended, in terms of Section 24(5) of NEMA (Act No. 107 of 1998), and includes an

assessment of the activities associated with the construction and operation of the Thermal Plant. As part of

this EIA process comprehensive, independent environmental studies have been undertaken in

accordance with the EIA Regulations. The conclusions and recommendations of this EIA are the result of

the assessment of identified impacts by specialists and a parallel public participation process.




The EIA Phase aimed to achieve the following:

» Provide an overall assessment of the social and biophysical environments affected by the proposed

project.

» Assess potentially significant impacts (direct, indirect and cumulative, where required) associated with

the proposed project.

» Identify and recommend appropriate mitigation measures for potentially significant environmental

impacts.

» Undertake a fully inclusive Public Participation process to ensure that Interested and Affected Parties

(I&APs) are afforded the opportunity to participate, and that their issues and concerns are recorded.

8.3 Overview of the Clayville Thermal Plant

The Clayville Thermal Plant utilising a Circulating Fluidised Bed (CFB) boiler will have the capacity to

generate up to 240 tons of steam per hour which is an equivalent of up to 60 MWe. The project site of

approximately 1.76ha in extent will comprise of the following infrastructure which has been included in the

scope of this EIA:

» CFB Boiler;



area;


» Condenser on site for the conversion of steam back to water;











office.

The thermal plant will combine high-efficiency combustion of various solid fuels with low emissions, even

when burning fuels with completely different calorific values simultaneously. The feedstock is proposed to

include syngas/natural gas and coal fines. The coal fines will be sourced from mines within the Delmas

and Middelburg areas, and will be transported to the site via truck. Syngas will be sourced from the

Bellmall Energy Syngas Plant situated at remote locations, and will be transported to the site via truck.

Natural gas will be sourced from Sasol via an existing gas pipeline situated along Spanner Road (western

boundary of the project site) within the Clayville industrial area.

A central steam generation facility (or thermal plant) on the proposed site within the Clayville industrial

area is considered to be desirable as a result of the zoning of the site, the location of the site within Zone 5




of the GPEMF, the opportunity to use a more efficient technology to raise steam compared to the

technologies currently used in the industrial area, the opportunity to reduce overall air emissions in the

industrial area, the opportunity to reduce reliance on heavy fuels and lower efficiency small boilers, the

availability of wastewater for treatment and use within the facility, and the opportunity to provide

employment.

8.4 Evaluation of the Proposed Project

The preceding chapters of this report, together with the independent specialist studies contained within

Appendices D to F, provide a detailed assessment of the environmental impacts on the social and

biophysical environment as a result of the proposed project, as identified through this EIA process. This

Chapter concludes the EIA process by providing a summary of the conclusions of the assessment of the

Clayville Thermal Plant and associated infrastructure. In doing so, it draws on information gathered as part

of the EIA process and the knowledge gained by the environmental consultants during the course of the

EIA, and presents an informed opinion of the environmental impacts associated with the proposed project,

as assessed by the team of independent specialist consultants.

From the conclusions of the detailed specialist studies undertaken, no fatal flaws, no-go areas or areas of

high sensitivity were identified within the project site (refer to Figure 8.1). Therefore, the entire project site

has been assessed as being suitable and appropriate from an environmental perspective for the

development and will not have a detrimental impact on any sensitive features present.

The potential environmental impacts associated with the proposed Thermal Plant include:

» Impacts on the air quality within the Clayville industrial area and associated impacts on human health;

» Impacts on traffic; and

» Impacts on archaeological resources.

8.4.1 Impacts on Air Quality and Human Health

Sensitive receptors (i.e. areas where the occupants are susceptible to the adverse effects of exposure to

air pollutants) have been identified within close proximity to the project site (refer to Figure 8.1 and

Appendix J):

» Clayville East (~1km east of the project site);

» Tswelapele (~1km west of the project site);

» Tembisa Provincial Hospital (~1.3km south of the project site);

» Clayville (~1.5 km north of the project site); and

» Olifantsfontein residential (~1.5 km south east of the project site).

The operation of the Clayville Thermal Plant will generate low emissions which will result in low ambient SO2,

NO2, CO and PM10 concentrations, and low ambient air quality impacts for the construction, operation

and decommissioning phase. The proposed development and associated infrastructure is therefore

unlikely to result in permanent damage to ambient air quality, and poses a low risk to human health.

Considering the results of the dispersion modelling and air quality impact assessment, the operation of the

Clayville Thermal Plant is expected to generate relatively low emissions from the CFB boiler for the coal

fines-only scenario, and significantly lower emissions for the Syngas and natural gas scenarios. These in

turn, result in ambient concentrations that are well below the NAAQS. Being a health-based standard,




ambient concentrations below the standard imply that air quality poses an acceptable risk to human

health.

The installation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s sites

and will therefore reduce different emission sources from the various boilers within the area. This is

considered to be a benefit in terms of air quality in the area.

The risk associated with the proposed development from an air quality and human health risk perspective

is therefore considered to be of low significance and acceptable. Recommended mitigation measures

must be implemented for the construction, operation and decommissioning phases in order to limit the risk

of any negative impacts.

8.4.2 Impacts on Heritage Resources

No significant archaeological, cultural landscape, built environment or battlefield sites were recorded on

the development site during the field surveys. No impacts on heritage resources are expected to occur

due to the development of the Clayville Thermal Plant. Based on the findings of the Heritage Assessment

the site is considered to be of low archaeological significance. The impact of the development of the

Clayville Thermal Plant on the archaeological nature of the site is considered to be of a low significance

with the implementation of the appropriate mitigation measures.

8.4.3 Impacts on Traffic

Impacts on traffic will be most significant during the construction phase due to an increase of heavy

vehicles on the existing road network. However, traffic volumes associated with the project are not

significant and can be accommodated on the existing road network with ease. However, the four-way

stop controlled intersection of Industry Road/ Nut Avenue is however already over capacity and it is

recommended that the intersection be signalised in consultation with the relevant roads authority. Overall

the impacts of the Thermal Plant on traffic will be of a medium to low significance with the implementation

of mitigation measures. It is concluded that the development of the Clayville Thermal Plant will not have a

detrimental impact on traffic or existing roads.

8.4.4 Cumulative impacts

Cumulative impacts and benefits on various environmental receptors will occur to varying degrees with

the development of the industrial sector and other developments within South Africa. The degree of

significance of these cumulative impacts is difficult to predict without detailed studies based on more

comprehensive data/information on each of the receptors and the site specific developments. The

current study assesses the cumulative impacts associated with the Clayville Thermal Plant together with

other industrial developments within the area on the basis of current and best available information, with

precautionary assumptions taken into account.

The potential for cumulative impacts are summarised in the sections which follow and have been

considered within the detailed specialist studies, where applicable (refer to Appendices D – F).




The cumulative effects or impacts considered:

» Cumulative impacts associated with the location and nature of the project, i.e. a thermal plant

located within the Clayville industrial area on Erf 457, Erf 459 and Portion 12 of Erf 508;

» Cumulative impacts associated with other relevant approved or existing and proposed developments

within the surrounding area of the proposed Clayville Thermal Plant project site (refer to Figure 8.2).

Considering the cumulative assessments undertaken for air quality, archaeology and traffic, it can be

concluded that the development of the Clayville Thermal Plant and other proposed developments in the

region are acceptable and will not result in an unacceptable loss or risk or an increase of the impacts. The

following can be concluded considering the Thermal Plant:

» The construction and operation of the proposed project will not result in an unacceptable risk to

human health through impacts on air quality, as is evidenced by the absence of exceedances of the

NAAQS for the various pollutants under consideration. The anticipated cumulative impacts of the

proposed project are therefore considered to be within acceptable limits from an air quality

perspective.

» The construction and operation of the proposed project will not result in an unacceptable loss of

archaeological or heritage resources, largely due to the absence of such sites within the development

area. The anticipated cumulative impacts of the proposed project are therefore considered to be

within acceptable limits from an archaeological and heritage perspective.

» The construction and operation of the proposed project will not result in an unacceptable impact on

the traffic of the local area, largely as a result of the location of the development site within an

industrial area. The Clayville Thermal Plant is considered acceptable when considering the potential

for impacts to traffic, and will not significantly impact on the national and regional road network of

South Africa and the areas surrounding the project site.

As the project site is located within an industrial area and within Zone 5 (Industrial and Commercial

Development Focus Area) as described by the Gauteng Provincial Environmental Management

Framework 2014, it can be expected that various developments within this area will be taking place in

future as the area was identified as being suitable for these types of developments. The installation of the

Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s sites and will result in a

reduction of different emission sources from the various boilers within the area. This is considered to be a

benefit in terms of air quality in the area.

The low potential for cumulative impacts and risks makes the location of this project site a desirable

location for further consideration provided that environmental impacts are mitigated to suitable standards

by strict control and implementation of the EMPr, as recommended within this EIA Report.

Considering the findings of the specialist assessments undertaken for the project, cumulative impacts

range from a low to moderate significance and can be considered as both positive and negative. Based

on a detailed evaluation, the cumulative impacts associated with the construction and operation of the

Clayville Thermal Plant and other developments in the region are considered to be acceptable. The

implementation of the EMPr and recommended mitigation measures would assist in mitigating these

negative impacts to an acceptable level as well as enhancing the positive impacts to a beneficial level.




Figure 8.1: Zoomed-out map of the sensitive receptors identified within close proximity to the project site (refer to Appendix J for A3 map).




Figure 8.2: Other relevant existing developments within the surrounding area of the Clayville Thermal Plant project site (refer to Appendix J for

A3 Map).




8.5 Environmental Costs of the Project versus Benefits of the Project

Environmental (natural environment, economic and social) costs can be expected at a local and site level

and are considered acceptable provided that the mitigation measures as outlined in the EMPr are

adhered to. These could include:

» The construction and operation of the Clayville Thermal Plant will initially have a marginal additive

effect on existing air emission concentrations during the use of coal fines as a feedstock and will

become negligible as clean fuels are introduced (i.e. Syngas and natural gas). The impacts

associated with the proposed development from an air quality and human health risk perspective is

therefore considered to be low.

» Traffic impacts associated with the development of the Clayville Thermal Plant which relate mainly to

an increase in traffic. The construction and future operations traffic volumes are moderate to low and

can be accommodated on the affected road network with ease.

These costs are expected to occur at a regional, local and site level and are considered acceptable

provided the mitigation measures as outlined in the EMPr are adhered to.

Benefits of the project include the following:

» The proposed project will utilise an existing waste by-product (i.e. coal fines) as a fuel source to

generate steam while reducing emissions within the Clayville industrial area which present a major

disposal challenge to the mining industry and are currently being stored as coal dumps and slurry

dams, which emit CO2. By utilising this waste by-product as a feedstock for a CFB boiler to produce

steam, provide an opportunity to convert a mining liability into a revenue stream. This is considered to

be a benefit from an environmental perspective as this would result in a reduction of the amount of

coal fines stored, and a subsequent reduction in CO2 emissions associated with this storage.

» The operation of the Clayville Thermal Plant will eliminate the need for small boilers on the off-taker’s

sites and will therefore reduce different emission sources from the various boilers within the area. This is

considered to be a benefit in terms of air quality in the area.

» The project will result in socio-economic benefits at the local and regional scale through job creation,

procurement of materials and provision of services and other associated downstream economic

development. These will transpire during the lifecycle of the development.

» The recycling of wastewater will result in a reduction of wastewater being disposed of to the municipal

system, thereby reducing the pressure on these systems and impacts on the environment.

» Development of the site provides an opportunity to manage and control the alien plant species

currently present within the site. This would reduce the risk of such species spreading in the surrounding

areas.

The benefits of the project are expected to occur at a national, regional and local level. These benefits

offset the localised environmental costs of the project, which are considered to be of moderate to low

significance.

8.6 Overall Conclusion (Impact Statement)

The findings of the independent specialist studies undertaken within this EIA to assess both the benefits and

potential negative impacts anticipated as a result of the proposed project conclude that:




» Impacts associated with the construction and operation of Clayville Thermal Plant and associated

infrastructure are expected to be of medium to low significance with the implementation of

appropriate mitigation measures.

» The operation of the project will reduce emissions from the various small boilers within the area.

» The project will reduce the pressure on municipal systems and impacts on the environment by

recycling wastewater currently being disposed of into the municipal system.

» The Thermal Plant will assist the municipality in reducing the level of unemployment through the

creation of jobs and supporting local business in a Municipality with a 28.8% unemployment rate.

» The project supports the creation of local employment, business opportunities and skills development

for the surrounding area.

» No environmental fatal flaws were identified to be associated with the proposed project provided that

the recommended mitigation measures are implemented.

The findings of the specialist studies undertaken within this EIA to assess both the benefits and potential

negative impacts anticipated as a result of the proposed project conclude that there are no

environmental fatal flaws that should prevent the Clayville Thermal Plant from proceeding, provided that

the recommended mitigation and management measures are implemented. The significance levels of

the majority of identified negative impacts have been reduced by implementing the mitigation measures

recommended by the specialist team during the EIA process. Environmental specifications for the

management of potential impacts are detailed within the draft Environmental Management Programme

(EMPr) for the Thermal Plant which is included within Appendix H.

With reference to the information available at this planning approval stage in the project cycle, the

confidence in the environmental assessment is regarded as acceptable, provided all measures are taken

to protect and preserve the surrounding environment.

8.7 Overall Recommendation

Based on the nature and extent of the proposed project, the local level of disturbance, the benefits

expected, the findings of the EIA, and the understanding of the significance level of potential

environmental impacts, it is the opinion of the EIA project team that the project can proceed on condition

that the mitigation measures specified in Chapters 6 of the EIA Report, the independent specialist Impact

Assessments contained within Appendices D to F, and those provided within the EMPr contained within

Appendix H of this EIA report are observed and implemented.

The following key conditions would be required to be included within an authorisation issued for the

project:

» All mitigation measures detailed within this report, as well as the specialist reports contained within

Appendices D to F, must be implemented.

» The Environmental Management Programme (EMPr) as contained within Appendix H of this report

must form part of the contract with the Contractors appointed to construct, operate and maintain the

Clayville Thermal Plant, and must be used to ensure compliance with environmental specifications and

management measures. The implementation of this EMPr for all life cycle phases of the project is

considered key in achieving the appropriate environmental management standards as detailed for

this project.




» The applicant should include the installation and operation of an Electrostatic Precipitator (ESP) for the

reduction of particulates and utilise sorbent for the reduction of SO2 emissions for the Thermal Plant.

» There should be a progressive move from initially using coal fines to using clean fuels such as Syngas

and natural gas during the operation phase of the project.

» The developer should engage with the relevant authority regarding the installation of traffic signals at

the Industry Road/Nut Avenue intersection to improve the intersection performance.

» A left-turn deceleration lane on Industry Road for vehicles entering the development or a second entry

lane should be introduced. Additional access to the site via Spanner Road can be created, to

improve on-site manoeuvrability, to reduce right-turn exit movements at the development access and

to reduce traffic impact on Industry Road.

» A letter confirming the availability of water and sanitation services must be obtained from the City of

Ekurhuleni prior to construction.

» A grievance mechanism procedure should be implemented through which I&APs can communicate

with the developer to ensure the protection of the constitutional rights of communities in the area

including the rights of neighbouring industries and businesses.

» Following the final design of the facility, a revised layout must be submitted to the GDARD for review

and approval prior to commencing with construction.

» A Chance Find Procedure should be implemented for the project site should any sites be identified

during the construction phase of the project. Should unmarked graves, buried archaeological or

palaeontological heritage resources be found during construction they should be reported to SAHRA

immediately.



References Page 119

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